Heavy metals are commonly used in electronic components such as printed circuit boards. As there are many types of circuit boards, it is difficult to use knowledge to categorize them as either hazardous or non-hazardous waste. Circuit boards may also contain batteries and mercury switches, both components that routinely are hazardous waste. Printed circuit boards destined for recycling are covered by the scrap metal exemption found in Delaware’s Regulations Governing Hazardous Waste (7 DE Admin. Code, 1302, Part 261 .6(a)(3)(ii)). This exemption allows used, whole circuit boards being recycled to be shipped without becoming subject to Delaware’s Regulations Governing Hazardous Waste.
Shredded circuit boards are covered under the exclusion for shredded circuit boards being recycled (7 DE Admin. Code, 1302, Section 261.4(a)(14)), provided the circuit boards are stored in containers sufficient to prevent a release to the environment prior to recovery, and are free of mercury switches, mercury relays, nickel‑cadmium batteries and lithium batteries.
Once removed, batteries and mercury switches can be managed under the Universal Waste Rule in Delaware’s Regulations Governing Hazardous Waste (7 DE Admin. Code, 1302, Part 273). Be aware that many of the mercury switches, mercury relays, nickel-cadmium batteries and lithium batteries used in the manufacture of circuit boards may be very small and may, on occasion, escape visual inspection. Therefore, directing the entire electronic component to a recycler, rather than first attempting disassembly, may prove most expedient.
Of course, while not preferable, the option remains to demonstrate through Toxicity Characteristic Leaching Procedure (TCLP) analysis that circuit boards are non-hazardous. When so demonstrated, non-hazardous circuit boards may be disposed in a permitted solid waste landfill. The Delaware Solid Waste Authority (DSWA) operates the state’s solid waste landfills. To dispose of non-hazardous circuit boards in a DSWA landfill, the DSWA must first grant written approval. The DSWA can be contacted at 302-739-5361.