HANDBOOK ON PROCEDURES FOR E-WASTE RECYCLERS
Electrical and electrical waste (e -waste) is one of the world's fastest rising discharges. According to a recent estimate 3,30,000 metric tons of e -waste are created annually throughout India (Information Technology Association of Manufacturers, 2007) and are expected to cross 8,00,000 metric tons by 2012. Throughout India, owing to the high rate of refurbishment and the substitution of electronic products, only a limited volume of e -waste is recycled. Much of the e-waste generated in the country is already recycled in the informal sector with low capacity and insufficient processing technologies who lead significantly to emissions load and environmental degradation. Some of the e -waste recyclers are active in the decommissioning of production e -waste. India needs sufficient e -waste recycling system to achieve end -to -end recycling.
The source of generation of E-waste are used electrical and electronic equipments like computers, mobile cell phones, personal stereos, including large domestic appliances such as refrigerators, air conditioners, etc., which are not fit for their originally intended usage and are meant for recovery, recycling or disposal.
E-wastes involve more than a 1000 distinct substances, all of which are toxic and potentially detrimental to the atmosphere and human health, unless they are treated in an environmentally sustainable way. The high rate of product obsolescence is a relevant factor for increased e -waste generation. Notwithstanding appropriate recycling and treatment services, these chemicals make their manner to scrap dealers and the supply chain of dismantlers that are in the informal sector. The dismantling activities are performed in a dangerous manner which leads to major environmental and safety problems.
The National Environmental Policy, 2006 (NEP) focuses of sustainable development and the need to encourage the reuse/recovery/recycling of useful waste materials, thereby preserving natural resources and reducing waste destined for final disposal to ensure that all waste is managed environmentally sound. The NEP further advocates giving the informal sectors legal status and strengthening. Given the high recyclable capacity of e -waste and comprehensive recycling activities in the informal sectors, the recycling policies in units must be channeled using environmentally sound technology.
E -waste Recycling Plant is an industrial enterprise on its own requiring clearances from different agencies to build and run the facility. Throughout the light of the need to control environmental pollution, the environmental clearances have become important among the various clearances today. Those facilities are to be built within the organized sector. However, to provide the unified plant with a support system, the operations currently conducted in the informal sector must be modified or duvetailed. This will enable the informal sector to be brought into the mainstream of the economy and would facilitate compliance with the law. The proposed mechanism for the e -waste facility is only an illustrative concept and during the construction of such facilities specific details must be sorted out.
The' E -waste recycling facility guidelines' are in accordance with the existing' Environmentally sound e -waste management guidelines' provided by the Ministry of Atmosphere and Forests, the Government of India and the Central Emissions Control Board (CPCB). These can be interpreted in accordance with the CPCB guidelines and every other advice / best practices / standards etc., also recommended by the Indian government.
2.Objectives & Scope of the Guidelines
The purpose of these guidelines is to provide advice to all those who are setting up an e-waste recycling facility in order to become familiar with the procedures and clearances needed for such facility.
These instructions are essentially a framework and reference manual for e - waste facility establishment and operations. The guidelines only provide information on the basic requirements and procedures for setting up a facility like this. The basic specifications can differ for each facility, based on the procedure used. All processes and mandatory criteria shall be in compliance with the law and regulations which apply at the time the application is processed.
The guidelines shall apply to all those who intend to set up e - waste recycling facilities in the formal sector and use environmentally sound recycling technologies to recover from e-waste the precious and other metals.
The rules shall not extend to such fluorescent lamps which are processed.
3. E-waste Scenario and prevailing recycling Practices
The electronics sector has emerged as Indian industry's fastest growing segment both in terms of production so exports. In the telecommunications and IT industry, the share of computer services has increased from 38.7 per cent in 1998-99 to an aggregate of 61.8 per cent in 2003 - 04. The transition in the IT sector coincided with liberalization, and the opening up of Indian markets along with a change in India's import policies against electronics, leading to import substitution of indigenously manufactured equipment. The Indian Computer industry is growing at a compounded annual growth rate of 25 per cent, according to estimates made by the Manufacturers ' Association of Information Technology (MAIT).
The growth of electrical and electronic products, usage rates and higher obsolescence rates lead to higher e - waste generation. The growing obsolescence of electronic products is also contributing to the tremendous import of used electronics. The generation of e - waste has significant economic and social impacts and the e - waste recycling industry also experiences an exponential growth. According to the estimate from the 2007 MAIT-GTZ evaluation, 3.30,000 metric tons of e - waste are produced in India annually and are expected to reach 4.70,000 metric tons by 2011. Nevertheless, only 19,000 metric tons of e - waste are estimated to be recovered and the majority of the e - waste can not be held accountable. There is no large - scale coordinated e - waste recycling system operating in India, and a number of small and medium - sized e-waste dismantling and recycling units are distributed in urban peri - urban areas of the cities. Although most of these services are in the informal sector, some of the recycling systems for e - waste is reported with the CPCB.
Sixty - five Indian cities contain more than 60 per cent of India's total e - waste. Ten states produce 70 per cent of India's total e - waste. Maharashtra ranks first in the list of e - waste producing states in India followed by Tamil Nadu , Andhra Pradesh, Uttar Pradesh , West Bengal, Delhi, Karnataka, Gujarat , Madhya Pradesh and Punjab. Mumbai ranks first among the top ten e - waste generating cities, followed by Delhi , Bangalore, Chennai , Kolkata, Ahmedabad, Hyderabad, Pune, Surat and Nagpur. In Chennai and Bangalore two small e - waste dismantling facilities are in place. Throughout India, there is no large - scale organized e - waste recycling facility, and all recycling is in the unorganized sector.
4. Environmentally Sound Recycling
Environmentally sound management as described in the Basel Convention and adopted in Indian Hazardous Waste Regulations is set out below:
Environmentally sound management and Recycling of hazardous waste implies and other waste implies taking all reasonable steps to ensure that hazardous waste or other waste is managed in a manner that safeguards human health and the environment from the adverse effects that may occur from such waste”
Synonymous with e - waste recycling and treatment performed, Environmentally Sound Methods (EST) should be used for recycling and disposal in such a manner that the environmental and human health consequences are not detrimental. As far as e - waste recycling is concerned, the Best Available Methods (BAT) and the methods used worldwide is set out in the CPCB guidance. Nevertheless, they could be updated on the basis of technological developments and access to such technologies from time to time.
5. Establishment and management of e-waste Recycling facility
E - waste Recycling Facility is an industrial operation on its own requiring clearances from various authorities to establish and operate the facility. In the organized sector these facilities must be built. The process starts with the project planning and preparation of the project document which will be in line with the planned operations and business plans for the project. The project planning, land acquisition and required licenses to be obtained from the agencies concerned in whose authority the unit is to be built, the unit will have to operate according to the specifications in each State.
The Environmental Clearances have become important among the numerous clearances today given the need to preserve the atmosphere and control pollution. The Detailed Project Report (DPR) should include the requirements for environmental compliance, and the investment made for the same. The purpose of these guidelines is to provide the details needed to pursue various environmental clearances and promote them in the process.
b. Environmental Clearance
The establishment of a recycling facility for e-waste recycling comes under Infrastructure Projects of the EIA notification dated September 2006 notified under the Environment (Protection) Act, 1986. It has similar requirements as the projects covered under the Treatment Storage Disposal Facility (TSDF).
Any person, who is likely to establish or take any steps to establish any type of E-waste recycling or processing, which is likely to discharge sewage or trade effluent into any stream or well or sewer or on land has to obtain consent of the concerned State Pollution Control Board. Similarly, any person, who is likely to establish or operate any e-waste recycling plant or process e-waste in any manner that is likely to cause air pollution is not permitted to discharge or cause the emission of any air pollutant in excess of the standards laid down by the concerned State Pollution Control Board. These emissions are regulated by the State Pollution Control Board/Committee and are subject to prior consent from the same.
The entrepreneur has to obtain the Consent for Establishment (CTE), which is the first and foremost requirement and is obtained prior to the setting up of the industry. If the industry falls under schedule I of Environment Impact Assessment notification of 2006, it requires Environmental Clearance (EC).
Procedure for Obtaining Environmental Clearances (EC)
The industrial unit which proposes to process e-waste is considered as any other industrial unit which handles hazardous substances and is liable to under the Environment Clearance Notification of 2006 as it causes pollute air and water.
3. Public Consultation
4. Project Appraisal
a. Expert Appraisal Committee
b. State Level Appraisal Committee
The Following information/documents have to be furnished for obtaining EC.
1. Project Report
2. Land/shed possession certificate
3. Location Map
4. Environmental Impact Assessment (EIA) Report
5. Environment Management Plan (EMP) Reports (for industries listed in Schedule Iof the EIA notification)
6. Water & materials balance
7.Proposed Pollution Control measures for water, air and solid and hazardous wastes
8. Detailed Layout map
9. Consent for Establishment (CTE)
c. Regulatory Compliances
According to the provisions of the Water (Pollution Prevention and Control Act), 1974 and Air (Pollution Prevention and Control Act, 1981, an entrepreneur forming or running a business or industry and is discharging / emitting contaminants into any resources of water or land / air is required to obtain the permission to pollute the atmosphere water / air known as the Pollution Control Consent comprising of CTE & CTO.
i. Consent for Establishment (CTE) (Consent to Establish)
An industrial unit's Consent for Establishment (CTE) as the word implies is prerequisite prior to any industry or process being established. Without CTE no industrial operation is permitted to begin. The CTE shall be collected from the State Pollution Control Board (State Board) concerned, through section 25 of the Water Act (Pollution Prevention and Control Act, 1974). As a first step, and in compliance with Rule 32 of the Water (Pollution Prevention and Control) Rules 1975, a proposal for grant of CTE should be sent to the State Board in Form OG/XIII (ref Appendix I).
Details relating to the position of the building, whether it is in a permitted industrial estate or private land or transformed ground, etc., must be furnished along with other documents relating to the possession or leased place, rented etc. Information relating to the manufacturing product, manufacturing process, raw materials used, water audit, waste produced, waste treatment operators
The Following information/documents have to be furnished for obtaining Consent forEstablishment (CTE):
1 Prescribed application forms I & XIII (to be downloaded from the concerned Board’s website or available free of cost from any of the office of the Board and should be submitted in triplicate along with the prescribed consent fee.)
2 Project Report
3 Land/shed possession certificate
4 Location Map
5 EIA & EMP Reports (for industries listed in Schedule I of the EIA notification)
6 Water & materials balance
7 Proposed Pollution Control measures for water, air and solid and hazardous wastes
8 Detailed Layout map
ii. Consent for Operation (CTO)
The Authorization for Service (CTO) must be secured 45 days before the device is (commissioned or) worked. Once the unit has been created, the entrepreneur will submit to the Pollution Control Board concerned for authorization in prescribed forms i.e. Form I and Form XIII along with the following documents to administer the same:
1. Form I and Form XIII. (appendix I)
2. Audited balance sheet.
3. Environmental Statement affidavit on Rs.100 stamp paper.
4. Prescribed consent fee in the form of DD.
A. Projects requiring Environmental Clearance
STEP 1: Preparation of Applications in Forms I & XIII
STEP 2: Submission of Application to be accompanied with requisite Consent Fee to RegionalOffice (RO) of jurisdiction
STEP 3: Acknowledgement of Receipt of Application
STEP 4: Application scrutiny and seeking clarification
STEP 5: Site Inspection
STEP 6: Inspection Report
STEP 7: Inspection report forwarded to SPCB by RO with recommendation
STEP 8: Scrutiny by concerned SPCB office
STEP 9: EIA report scrutiny by SPCB
STEP 10: Public Hearing
STEP 11:Technical Advisory Committee Review of Application
STEP 12: Consent Clearance Committee
STEP 13: Issue/Refusal of Consent
B. Projects not requiring Environmental Clearance
STEP 1: Preparation of Application
STEP 2: Submission of application with requisite Consent Fee to Regional Office of jurisdiction
STEP 3: Receipt of CTE application
STEP 4: Acknowledgement of Receipt of Application
STEP 5: Application scrutiny and seeking clarification
STEP 6: Site Inspection & inspection Report
STEP 7: Inspection report forwarded to SPCB with recommendation
STEP 8: Scrutiny by concerned SPCB office
STEP 9: Consent Clearance Committee
STEP 10: Technical Advisory Committee Review of Application based on Consent Clearance Decision.
STEP 11: Issue/Refusal of Consent based on TAC recommendation
Documents to be enclosed:
1. Copy of Executive Summary
2. Copy of EIA Report & Form I
3. TOPER Sheet Extract
4. Detailed Project Report
5. Clearance of High Level Committee
The facility should be inspected by the SPCB and upon being satisfied, the CTO is issued. The unit is not permitted to operate till the CTO is issued.
iii. Authorization for Handling Hazardous Wastes
E - waste was included as a form of waste in the 2008 changes to the Hazardous Wastes (Management and Management) Laws, because e - waste contains hazardous constituents. In addition to that, e - waste handling includes dangerous operations. Under these laws, by submitting the application form (Form-I) set out in Appendix III, all individuals managing e - waste are expected to obtain authorisation.
iv. Registration as Recyclers
The 2008 changes to the Hazardous Wastes (Management and Handling) Regulations have included e - waste as a waste type. Provisions were made in Chapter III, Rules 8 - 10, for the registration of all e - waste recyclers with the Central Pollution Control Board ( CPCB) The category of e - waste was classified under the categories of toxic recyclable waste in Schedule IV of those regulations. Under these rules all those participating in e - waste recycling to go through the tedious registration procedure including those active in dismantling operations. The application for registration should be submitted in Appendix IV, Type 5
v. Transboundary Movement of e-waste
Every transboundary movement (importation and export) of e - waste shall comply with the procedures set out in Chapter IV of the 2008 Laws on Hazardous Wastes (Management, Handling and Transboundary Movement) and with the provisions of the Basel Convention on the Regulation of Transboundary Movement of Hazardous Wastes. Under the laws on hazardous waste as well as under the Basel Convention, e - waste has been classified as hazardous waste since it is known to contain various hazardous components such as cadmium , lead, asbestos, brominated flame retardants and polychlorinated bi-phenyls etc. The waste electrical and electronic assemblies or components were included in those provisions in Schedule III, Section A. Those e - waste containing hazardous constituents to the degree that they show danger characteristics specified in Schedule III, Part B of these laws are included in List A (A 1180), equivalent to Annex VIII of the Basel Convention, including the importing country's prior written consent (PIC). The e - waste not comprising or polluted with the dangerous constituents shall be placed in B 1110, equivalent to Annex IX of the Basel Convention which would not attract PIC unless required by national law. In India all e - waste transboundary movement requires Photo. The demand for export / import approval for e - waste shall be submitted to the Central Government, Ministry of Environment & Forests in Forms 7 & 8 along with a full cover insurance policy. All shipments should be accompanied by Form 9 set out in those rules.
vi. Environmental Monitoring & Compliance
The instructions, best practices and specifications for setting up and operating e - waste recycling facilities have been described in the e - waste management guidelines published by the Ministry of Environment and Forests. These guidelines also provide Best Available Technology and the Global Scenario to make it easier for the e - waste recycler to gain insight into the system required.
The information for developing an Integrated E - waste Management Facility are provided in Chapter 7 of this paper. The required e - waste handling procedure was given. The protocols for establishing and managing e - waste recycling facility were identified. This chapter further enlists the criteria for enforcement with existing regulations. Links to access the details for the same were provided.
This handbook of procedures is a reference document providing guidance for obtaining the necessary environmental clearances, consents and other permits for the environmentally sound management of e- waste.