DNR Guidance on Circuit Board Disposal
EPA has stated that circuit boards frequently fail the TCLP for metals, and are therefore hazardous waste when disposed. EPA has made a policy decision that used circuit boards are subject to regulation as scrap metal under 40 CFR s 261.6(a)(3)(iv), and are therefore exempt from RCRA Subtitle C (hazardous waste) regulation when recycled. EPA has also stated that unused circuit boards are subject to regulation as commercial products - they may be hazardous waste when disposed if they fail the TCLP, but are exempt from hazardous waste regulation when they are recycled.
This interpretation is found in an August 26, 1992 memo from Sylvia Lowrance, Director of the Office of Solid Waste; an October 15, 1991 memo from Barbara Roth, Project Officer in the Office of Solid Waste, and a July 5, 1990 Memo from Thea McManus, Project Officer in the Office of Solid Waste.
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For additional information, please contact staff in UWM's Environmental Affairs Program at x4999 or x2883.
Updated October 2, 2007 by SAK