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Escrap License?

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    LadyScrappers started this thread.
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    Escrap License?

    Hi All,



    Has any of you been asked for an e-scrap license when picking up e-scrap? I have a chance to get 80-90 hard drives but the person wants to know if I have a license. I checked into it, and you basically have to have a facility, go through a class, pay a lot of money and get a license. I think the whole point of it is just to certify that you're not going to dump it somewhere, and that it's going straight to a refiner. Has anyone else run into this?


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    Quote Originally Posted by LadyScrappers View Post
    Hi All,
    Has any of you been asked for an e-scrap license when picking up e-scrap? I have a chance to get 80-90 hard drives but the person wants to know if I have a license. I checked into it, and you basically have to have a facility, go through a class, pay a lot of money and get a license. I think the whole point of it is just to certify that you're not going to dump it somewhere, and that it's going straight to a refiner. Has anyone else run into this?
    Maybe that's where the "certificate of destruction" we were talking about a little while back might be all they need for security??
    P & M Recycling - Specializing in E-Waste Recycling.
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    All depends what type of license. I am Level 4 (top level) NH DES certified for my work. The problem is that then, DES will want to know why you want the license and then may make you get a Facility permit. Remember that in NH you officially need a Facility permit to scrap any electronics for recycling. Here is what DES HW-25 states:

    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.

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    not at the level most of us are handling it. at least here in Ohio. I let customers know that I am NOT burning, melting, grinding, refining, shredding, etc anything that they release to me. I do, however, break it all down and take it to "reliable" companies that do. Here are the laws in Ohio.

    Does an Electronic Equipment Recycling Facility Need a Permit from Ohio EPA?
    Ohio's hazardous waste rules -->do not require,<-- a facility that recycles electronic equipment to obtain a hazardous waste permit. However, the owner/operator of the facility must evaluate any waste generated from the recycling process and manage it accordingly. Ohio EPA's Division of Air Pollution Control may require the owner/operator to obtain an air permit for its recycling equipment. The Division of Surface Water or the publically-owned treatment works may require permits for waste water discharges. The Division of Solid and Infectious Waste Management may also require a transfer facility license.

    If they are looking for a "document of destruction" form from you, so that they know that the drives have not been just wiped, see if your buyer can work with you to provide that info. I recently did a removal for a large mailing company. They were fine, with just a letter from me, stating the date and means by which the drives were destroyed. JUST KNOW THAT THE LIABILITY THEN SHIFTS TO YOU for the drives and there content, so make SURE THEY ARE NOT USED IN ANOTHER MACHINE AND ARE DESTROYED! lol Not that I think you, LS, are not aware of that, is more for those who do NOT and may read this. good luck and God Bless, BroJer

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    I have a chance to get ten pallets from a school but they want me to be certified with the state. Gonna start researching what all is required to get certified.

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    LadyScrappers started this thread.
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    Quote Originally Posted by bpatnoe View Post
    All depends what type of license. I am Level 4 (top level) NH DES certified for my work. The problem is that then, DES will want to know why you want the license and then may make you get a Facility permit. Remember that in NH you officially need a Facility permit to scrap any electronics for recycling. Here is what DES HW-25 states:
    Unfortunately, I think this is what they are talkng about. My local scrap yard takes any kind of escrap for 10 cents/lb and when I asked them if I could buy it from them, they told me that they could only sell to someone with this permit (which they have). I asked them how they got their permit, and they told me they had to go through a class and pay a lot of money, and that they are subject to periodic unanounced inspections. I'm not even zoned commercial, so technically have no facility.

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    Do they ask for a license from the people bringing it to the yard?

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    LadyScrappers started this thread.
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    No, I've never been asked. It's the yard or facility that needs to be licensed.

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    Quote Originally Posted by mikedmissouri View Post
    I have a chance to get ten pallets from a school but they want me to be certified with the state. Gonna start researching what all is required to get certified.
    Getting the cert from the state is not the same as a r2 or ISO9001 but simply that you are a e-waste recycle and they may come out and view your land and some other small things but the cost is low.
    My company name was Easy Recycle but has since been closed
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    Quote Originally Posted by LadyScrappers View Post
    No, I've never been asked. It's the yard or facility that needs to be licensed.
    EXACTLY. So, they need to see one to SELL to you, but you do NOT need one to SELL to them. It still seems to me that for an individual, the same laws do not apply. I can understand once it enters into their stream, because they are a company with land, equipment, buildings, employees, a paper trail of in/out etc, that it may make sense why they can not SELL, unless it is to someone who is licensed. If there was a law, or regulation, that required you to have a license to SELL to them, they would have to ask that ANYONE show proof that they have a license. At the basic level, this would mean that ANY BUYER or SELLER of E-Scrap in NH would have to be trained and get a license. I hope I am getting my thoughts across and hope you can get a direct answer.
    Either I learn sumptin new every day, or I go to bed more confuzzeled than when I got up Have a great weekend and good luck! BroJer

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    I am currently seeking this in PA (if simular to NH, I don't know) The key loop hole is; you have to have a license to process the waste. You can't break down, like a computer into its parts and store them until you sell them. If you store all materials inside and have no runoff of water, so far it seems easy to get. Although you have to jump through 8 or 10 forms and pay $. And yes, this is to prevent evironmental hazzards or illegal export. And I am certain the goverment likes the money it charges for the fees and license.

    Perhaps you can let the person know you are taking the e-waste to responsible processors of e-waste (that are licensed) and because your experience and knowledge of the business you can make a little money to help get your processing license for your state. It is not lying if you had money you would probably get one right? Anyway goodluck!

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    Yeah, it will probably take me about a year to be able to meet IN regs for a license, only because I don't have a big enough building to store my stuff in. Thats the only setback I have....... the rest is cake.
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    Quote Originally Posted by LadyScrappers View Post
    Unfortunately, I think this is what they are talkng about. My local scrap yard takes any kind of escrap for 10 cents/lb and when I asked them if I could buy it from them, they told me that they could only sell to someone with this permit (which they have). I asked them how they got their permit, and they told me they had to go through a class and pay a lot of money, and that they are subject to periodic unanounced inspections. I'm not even zoned commercial, so technically have no facility.
    And here I thought NH was the "Live Free Or Die" state! What an impediment on small local business. It seems to me the burden of proof should be on the state, to prove that you have behaved irresponsibly with materials. I hope the Porcupine people have some luck in rolling back these unreasonable demands.

    Quote Originally Posted by Hypoman View Post
    Yeah, it will probably take me about a year to be able to meet IN regs for a license, only because I don't have a big enough building to store my stuff in. Thats the only setback I have....... the rest is cake.
    Am I wrong, but in Indiana aren't we pretty much good to go unless we have 23 tons or more of material at our physical location?

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    Lady scrapper: There was a thread on this site that talked about data destruction, how they would drill a hole in the HD and then take a picture and send it to the customer. So if the client is worried about data destruction you might want to look into something like that. But, if they are worried about ewaste being taken to the proper facility, I would just tell them the truth. Tell them where you are going to take the HDs and reassure them that the place is licensed. You can give them the info to the facility and also follow up and let them know when it has been delivered.

    Im here in CA. and the laws can get quite confusing. I have a business permit for a mobile service because the permit to store and dismantle is 15-30 thousand dollars. The notification for the intent to handle e-waste with Department of Toxic Substance control requires a facility location on the application but, the city doesnt allow that I have a facility. Some have told me that I can just put my home address as the facility location and that should be ok. There are no clear instructions on the DTSC website that explain the application process and the 1-800 hotline is incredible hard to get a hold of someone.

    It is important to understand the different terms when going through this process.
    Handler: a handler handles and could stores universal waste but, isnt allowed to treat or recycle (break down the items).
    Recycler: A recycler is allowed to break items down but, with many items as you break them down their classification changes from "universal waste" to "hazardous waste". Because of this, to become a recycler you have to get more permits in order to handle "hazardous waste".

    Once you become a "Handler" you can only take your e-waste to certain locations. Lady Scrapper, I think this is why you couldn't buy the e-waste from the guy at your yard because he has to send it to a certain facility because he is a "handler".

    Well this is how I understand it. I hope this helps.

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    Quote Originally Posted by mrsamsonite View Post
    Lady scrapper: There was a thread on this site that talked about data destruction, how they would drill a hole in the HD and then take a picture and send it to the customer..............
    This does not kill the hard drive. The data can still be read as the disks will spin up still. There will be data loss but ONLY where the drill hole was made.

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    LadyScrappers started this thread.
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    If it were just a matter of the hard drives, I could just take them all out and give them back to the owner. I will find out tomorrow about the 80-90 hard drives. I might be able to strike a "don't ask don't tell deal". We'll see. Thanks for all your information and help, guys!

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    Quote Originally Posted by Enoch43 View Post
    Am I wrong, but in Indiana aren't we pretty much good to go unless we have 23 tons or more of material at our physical location?
    Her is the very first exemption from 329 IAC 16-3-1:


    (1) A site where there is electronic waste in an amount equal to or less than forty-six thousand (46,000) pounds or twenty-three (23) tons enclosed in a building or an enclosed lockable trailer.

    This is my only problem. I did not anticipate I would receive such an influx of material so fast, thusly, my current building cannot contain what I have and I do not have a trailer to store it in. Other than that minor setback, all the other exemptions are easy to deal with( I know we don't have to meet all the exemptions, but I like having my butt covered, ya know?). If we keep growing as fast as we have been, we will be getting another building fairly quickly.

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    Here is how Ohio views handling e-waste...

    "Under Ohio's provisions, computer CRTs are not regulated as hazardous wastes if the generator has them recycled. -->Ohio considers discarded integrated circuits from computer systems to be scrap metal. Scrap metal is not regulated as hazardous waste if it is reclaimed or recycled"<--

    Am glad to be a Buckeye...for now

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    Quote Originally Posted by LadyScrappers View Post
    Hi All,

    Has any of you been asked for an e-scrap license when picking up e-scrap? I have a chance to get 80-90 hard drives but the person wants to know if I have a license. I checked into it, and you basically have to have a facility, go through a class, pay a lot of money and get a license. I think the whole point of it is just to certify that you're not going to dump it somewhere, and that it's going straight to a refiner. Has anyone else run into this?
    LadyScappers, I would suggest buying an hour of a lawyer's time to get the legal skinny directly from an expert familar with local laws and regulations.

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