Basic Training

Document destruction companies are almost inevitably presented with opportunities to enter the electronic information destruction business.

Before jumping at the opportunity, there are a number of factors to consider and certainly a great deal to learn before taking possession of hard drives or storage media for destruction purposes.

Afew of the most important points document destruction companies should be aware of before expanding into this field follow.

Computer monitors hold a cathode ray tube (CRT) that contains 5 to 8 pounds of lead. Once the CRT is broken, the lead dust is released into the air, along with highly toxic phosphor dust.

These hazardous dusts can be inhaled by employees, not to mention carried home on clothing, which could expose their childen to the lead. OSHA requirements specific to lead can be found in 29 CFR Ch. XVII, s/s 1910.1025. Additionally, most circuit boards also contain tin-lead solder, so this must be considered as well.

A computer hard drive contains a circuit board, as does virtually anything electronic today. Be sure to take every safety precaution with your employees and customers by implementing strict environmental and safety policies, as well as documenting and auditing them.

Shredding electronics will result in residual waste that must be disposed of properly. Unless you go into the equipment destruction business on a very high-volume basis, the residual material will have little to no resale value.

Make sure that you have qualified, permitted materials processing facilities to handle the residual waste properly. Review their permits and insurance. At no point should you ever send electronics material (shredded or in whole form) to a landfill.

This is a violation of two specific Federal laws. The Resource Conservation and Recovery Act (RCRA), commonly referred to and pronounced as "rickra," [42 U.S.C. s/s 6901 et seq. (1976)] specifically bans hazardous waste from landfills. Lead has been recognized as hazardous waste by the U.S. EPA for quite some time. This is because lead exhibits the characteristic of toxicity as determined by the Toxicity Characteristic Leaching Procedure (TCLP) test.

CRTs from color monitors and color televisions consistently exceed the regulatory limit for lead when tested using the TCLP.

In light of their weight and size, CRTs comprise a significant portion of the overall monitor or television and will cause the entire unit to be considered hazardous waste. It should be assumed that non-residential color monitors and color TVs destined for disposal are hazardous waste unless the generator has tested their equipment to show that it is not hazardous or has other supporting data from the manufacturer.

The second law violated when significant shredded electronics are landfilled is the Emergency Planning & Community Right-To-Know Act (EPCRA), which can be found in EPA’s SARA Title III regulations.

Specifically, some companies that have more than 10 full-time employees and dispose of more than 100 pounds of toxic chemicals (lead, in this case) are required to report an inventory of the material that was released.

Finally we get to the very scary prospect of being named in a Superfund clean-up action. Should your trash hauler be named as a defendant in a Superfund clean up, its attorney will naturally look for customers to share in the substantial clean-up costs. They will look to the most likely sources of the contaminants, sources called "Potentially Responsible Parties," or PRPs.

Once named as a PRP, it is extremely difficult and expensive for a company to defend itself. Having routinely disposed of electronic equipment could make a company a likely PRP in any Superfund litigation.

A wide array of electronic equipment today contains some kind of hard drive or other data storage device. These devices contain data; some important, private, or sensitive; some obsolete, embarrassing or insignificant. Once the equipment is removed from the customer site, the protection of the data becomes your responsibility. It is very easy for someone to pick up a hard drive, laptop, PDA or other device while you are loading the truck or talking with your customer. Well-written policies that are routinely audited will keep devices from being stolen or "disappearing."

The world of technology moves at a staggering pace. What is advanced today is obsolete tomorrow. New methodologies for recovering data or hacking systems routinely crop up. Having professionals on staff that are certified in their area of expertise by industry recognized organizations will keep your company on the cutting edge of electronic data destruction.

When doing digital data destruction of any type of media specifically for the purpose of reselling or reusing the media (hard drives, tapes, CD-RWs, etc.), make sure that you have a well-designed quality control process in place.

Attempt data recovery on appropriate random samples of media to validate the reliability of your data destruction process. Have absolute policies in place for physical destruction of any media that fails quality control or that fails to properly complete the wiping process.

Our company, Reclamere, is an electronics recycler. We also provide certified data destruction services for our customers by digitally destroying data on computers or by physically destroying devices upon which data reside. This is a relatively new service in information destruction; however it closely parallels paper shredding in many ways.

Disposal and recycling should not be confused with certified data destruction. Like paper shredding, it is important that the vendor has sufficient insurance and can demonstrate clear chains of custody leading up to destruction.

Therefore, it is imperative that extreme caution be used when dealing with electronics destruction. Like any new business venture or service offering, proper planning and due diligence will increase the likelihood of success and mitigate potential problems.

If the idea of working in the area of electronics recycling is something you are entertaining, consider partnering with an existing electronics recycler. The company should be insured, permitted and operate to the same high standards your company has set forth. Often, partnering with an existing reputable company is the best way to see if the market potential exists in your region to support the endeavor as a stand-alone business model. n