Frequent Questions

If a batch of whole circuit boards contains mercury switches, mercury relays, nickel-cadmium batteries, and lithium batteries, but the items are removed prior to shredding, are the shredded circuit boards eligible for the Section 261.4(a)(14) exclusion?

Circuit boards that have mercury switches, mercury relays, nickel-cadmium batteries, and lithium batteries removed prior to shredding, and that are containerized prior to recycling, are eligible for the exclusion in Section 261.4(a)(14). EPA limited the scope of the exclusion to circuit boards free of these items to prevent potential releases of mercury, cadmium, and lithium to the environment. "Free of," however, does not mean that the whole circuit boards never contained these items; it simply means these items were not part of the batch of circuit boards when shredded (62 FR 26013; May 12, 1997). If these items are removed from the whole circuit boards prior to shredding, the boards remain within the scope of the exclusion. On the other hand, shredded circuit boards that are not free of mercury switches, mercury relays, nickel-cadmium batteries, and lithium batteries are solid wastes and potentially hazardous wastes when recycled.

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