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I. EXECUTIVE SUMMARY

The problem of electronic waste (e-waste) is growing at an unsustainable rate. E-waste is now the fastest growing, and most toxic, component of municipal garbage. Local governments are facing huge costs to handle e-waste, and even greater costs if they do not capture this toxic stream and handle it in an appropriate manner.

Recycling is both a means of preventing the land disposal of toxic metals in e-waste and recovering some value. The Computer TakeBack Campaign, an advocacy coalition, is developing and campaigning for appropriate models for managing e-waste. (For more information about the campaign, its goals and work see Computer TakeBack! Campaign.

This case study compares two very different models for recycling obsolete computers and electronics hardware that have been created by the two largest computer makers in the U.S. -- Hewlett Packard's partnership with Micro Metallics of Roseville, California, and Dell Computers' (recently renamed Dell, Inc.) partnership with UNICOR, the Federal Prison Industry.

Our methodology included visits to both sites to examine the facilities for a number of characteristics:

• Transparency and accountability to the public

  Handling large amounts of e-waste poses risks of toxic contamination to workers and surrounding communities if conducted carelessly. Thus, the most basic criterion that employees and citizens should rightfully expect from any recycling operation is that it be open to public inspection.

• General compliance with occupational health and safety standards

  Observance of health and safety standards in the workplace is important for protecting workers from exposure to toxics. It is also a powerful indicator of broader compliance with environmental requirements. Well-trained workers, who are fully protected by the law to seek advice and take action to protect their health and the environment without fear of reprisal from their employer, are the most effective environmental protection. Operations that expose workers to hazards also frequently fail to protect communities around their facilities from dangerous emissions. Seldom does an industrial facility with a well-managed occupational health and safety program, and workers who are fully empowered to initiate corrective actions, violate environmental standards.

• Use of best recycling practices and their potential for wide adoption by the private sector

Electronic waste is a fairly new category of resource recovery. As the nation responds to this growing challenge to waste management systems and the environment, we must quickly develop the infrastructure required to handle huge volumes of e-waste. How do we build this new segment of our economy so that it is thriving, sustainable and independent of the public treasury?

This study found that the two facilities differed dramatically in their transparency to the public. The Atwater facility exhibited a "fortress UNICOR" mentality, allowing only restricted access to investigators. UNICOR failed to respond to repeated requests to allow an industrial hygienist trained in occupational health and safety to inspect its facility, approving the visit too late for its findings to be included here. During a visit by other inspectors for this study, both investigators and inmates were forbidden from speaking with each other. Fortunately, the investigators were able to supplement their observations with testimonials from inmates, which are presented anonymously in this report to protect prisoners from reprisal. The Atwater facility refused to provide air quality test results, claiming that this information would have to be sought through a Freedom of Information Act request addressed to the federal Bureau of Prisons.

In contrast, the Micro Metallics - Hewlett-Packard facility allowed our industrial hygienist to inspect freely, permitted investigators to speak informally with employees, and provided air monitoring and employee blood -lead test results.

Safety and health standards were very different at the two recycling operations. At Atwater, UNICOR's primitive practice of manually smashing leaded glass in cathode ray tubes unnecessarily exposed workers to risk of toxic contamination and cuts. Security restrictions on the kinds of tools available to prisoners made their work less efficient and more dangerous. Workstations were not designed to avoid ergonomic hazards. One inmate reported that "Even when I wear the paper mask, I blow out black mucus from my nose everyday. The black particles in my nose and throat look as if I am a heavy smoker. Cuts and abrasions happen all the time. Of these the open wounds are exposed to the dirt and dust and many do not heal as quickly as normal wounds." Inmates reported that those who sought to improve conditions faced discipline and loss of their jobs.

At Micro Metallics - HP, hazardous tools such as hammers were eliminated in favor of mechanized systems, such as crushers, that reduce worker exposure to toxics. The facility's workstations were designed to reduce ergonomic hazards. An intranet database allowed workers to access information on hazardous materials and optimal methods for safe disassembly.

The strikingly dissimilar picture at the two operations offers a contrast between some of the worst and best recycling practices. UNICOR's operation is organized primarily to maintain a maximum-security facility, rather than to maximize the efficiency with which e-waste is sorted and disassembled. Its prison warehouse is organizationally and technologically backward. Cheap labor, paid .20 to $1.26 per hour at Atwater, offers little incentive to invest in worker productivity. In addition, prison workers have few rights and little ability to improve health and safety conditions. Inmates toil outside the protection of state and local environmental and labor regulations that private sector recyclers must follow. Prison laborers are not considered employees and are not protected against retaliatory acts by their employer (UNICOR) under the Fair Labor Standard Act. Inmates are not allowed to unionize or to serve on the prison health and safety committees.

In contrast, Micro Metallics - HP had developed efficient warehousing systems that electronically track materials throughout the recycling process. The facility was staffed by union workers paid a living wage. Non-management employees sat on the company's health and safety committee. They helped create a workplace that was open to public inquiry and able to respond to state and local regulatory agencies.

UNICOR, a publicly subsidized prison industrial operator, used practices disturbingly similar to those found in developing nations, which were exposed in the 2002 report, Exporting Harm. Inspectors found harsh conditions, very few worker rights and protections that are guaranteed to hazardous waste recycling workers in the US, and lack of disclosure of its practices to the public. The Micro Metallics - HP facility, a private sector operation, had much higher levels of demonstrable health and safety and environmental safeguards. In addition, while Hewlett-Packard has committed to a policy of not exporting hazardous e-waste to developing countries, UNICOR has acknowledged that e-waste processed in their facilities is likely exported overseas to foreign countries for final disposition.

Because of the lack of transparency surrounding the UNICOR facility, its inefficient and unnecessarily dangerous recycling practices, and the undetermined taxpayer subsidy that underpins its operation, planners and policy makers will be able to learn much from their operations about how not to set up a sound e-waste recycling program. The Micro Metallics facility, while not yet offering comprehensive solutions, offers a far better model for further study and imitation.

These recycling operations suggest two paths for the future of e-waste recycling in America. One path leads toward efficient, transparent, modern facilities staffed by free labor, possessed of their rights as contemporary employees, able to protect themselves and nearby communities from harm. The other path descends into a closed, Dickensian world of prisoners condemned to dangerous work for little pay under backward conditions. Depending on the path we choose, e-waste recycling can contribute to community economic development and environmental protection, or can become the equivalent of breaking rocks on a high-tech chain gang.