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Listed below are comments received from stakeholders relating to the
issue area of
definitions
Comments are received through
stakeholder meetings and correspondence. Due to transcription and/or space
limitations, the following may be paraphrased from the original comment
received.
Comments/Questions (received as of March 17, 2004)
- [Regarding] the definition of "covered electronic device"
under 42463 (f) (2)—What is the current thinking about your interpretation and
how is it aligned with the definition in 42463 (f) (1)? What to do with aftermarket products? Do they
apply?
- How quickly will we (manufacturers) get an interpretation about what
products are covered? How do we notify the retailer if we don’t have the
interpretation? What do we need to do by April 1?
- RCRA states that it is the waste generators responsibility to
determine if its waste is hazardous. However 42463 defines a "Covered
electronic device" as a: cathode ray tube, cathode ray tube device,
flat panel screen, or any other similar video display device with a
screen size that is greater than four inches in size measured diagonally
and which the department determines, when discarded or disposed, would
be a hazardous waste pursuant to Chapter 6.5 (commencing with Section
25100) of Division 20 of the Health and Safety Code. Does the
department automatically determine these devices to be hazardous waste
if the generator tests the waste and finds that it has a toxicity
characteristic (TCLP exceeds the alowable threshold)? Is the generator
relieved of its responsibility to test its waste?
- We would assert that "covered electronic device" should include any CRT or CRT device as defined under the DTSC's existing emergency regulations. The whole unit should be considered and not just the screen. We believe a great amount of confusion would result if the interpretation were adopted that any device with a screen would be covered e.g. the screens from a palm pilot, a microwave oven, a DVD player. When DTSC's regulations that prohibit the disposal of all other electronic devices in landfills take effect in 2006, then perhaps, another law can be passed that will provide funding for the collection and recycling of these additional items.
- Define what "cost free" means.
Every effort has been made to accurately reflect
stakeholder input. Please direct any corrections or additional comments in
alignment with guidance on the Stakeholder Input page.
Stakeholder Input Page |
SB 20 Home Page
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