In a recent article, we recounted many of the methods members told us they use to dispose of obsolete computer equipment. These included employee giveaways, donations to charity, and, in one case, an execution (of an old mainframe). A couple of folks pointed out that old computers are considered toxic waste in many states and must be disposed of properly. And this is not just a tree-hugging reaction.

In fact, the federal Environmental Protection Agency (EPA) classifies computer equipment as hazardous waste—in particular, the cathode ray tubes (CRTs) found in computer monitors. The latter classification is based on the high concentration of lead found in all cathode ray tubes.

This is the EPA’s position on the disposal of CRTs:

Used computer monitors or televisions generated by households are not considered hazardous waste and are not included under federal regulations.

Donations or Resale: Monitors or televisions sent for continued use (resold or donated) are not considered hazardous waste.

Small Quantities Exempt: Businesses or other organizations are not regulated under most federal requirements if the facility discards less than 100 kilograms (about 220 pounds or eight monitors) of hazardous waste per month. (This waste must still go to facilities authorized to receive solid waste.)

Large Quantities: Facilities that generate more than 100 kilos per month of hazardous waste are regulated under federal law. CRTs sent for disposal must be manifested as hazardous waste and sent to a permitted hazardous waste facility. The facility must maintain records onsite for three years documenting the type of materials disposed of, with whom, and when. CRTS sent for recycling are also subject to these same regulations, but the federal EPA is in the process of reclassifying CRTs as universal waste, which will streamline the reporting and record-keeping requirements.

(State EPA regulations vary widely, so you may want to ask your company legal council what the regulations are in your state.)

Newtech Recycling, Inc., is a “total recycler,” a Class D licensed organization whose business it is to properly dispose of obsolete and hazardous computer equipment. Joe Kostick, facility manager for Newtech, whose customers include Okidata, said that it works with its customers in three ways.

For companies that wish to sell used equipment to their employees, Newtech will bring the equipment in, test it, and clean out any proprietary information. It then offers the company a spreadsheet of which equipment is ready to be sold to the customer’s employees.

If the customer doesn’t want any of the equipment listed in the spreadsheet, Newtech will buy it at fair market value and then resell it.

If the equipment is too old, Newtech dismantles it. “We have a patented system for disposing of monitors and tubes. We take the monitor apart and separate it into components. Plastics get recycled, the circuit boards get recycled, the leaded glass is taken out and broken, and the metal screen inside is taken out,” Kostick said. What some people don’t realize, Kostick said, is that the solder used on circuit boards and in wiring is lead, which is a hazardous component. Once these components are extracted, they’re taken to a refinery. Kostick said his company has a refinery for glass only and one for lead only.

Kostick strongly cautions companies looking for a recycler to be very careful. You have to do due diligence and find out “where the equipment is going.” Some companies ship hazardous material overseas to landfills. (For more information on this, Kostick refers to The Basel Action network, an international network of activists seeking to put an end to economically motivated toxic waste export and dumping in poorer, less-industrialized countries.) “Some companies will claim that they don’t export the equipment overseas, but what they’re actually doing is selling the equipment to a domestic exporter.”

So it pays to do your research. And it’s also worth the effort. Properly recycling and disposing of old computer equipment is no longer just a matter of what’s convenient. It’s an environmental and legal issue.