Any person, agency, or organisation engaged in dismantling e-waste into its components is called a dismantler. Dismantling is usually a manual operation as the separation of various components of e-waste has to be done carefully so that the component is not destroyed in the process. Functional components can be straightaway sent to be used as spares while other parts are sent to authorised recyclers depending upon the nature of the part. Components which may contain hazardous constituents must be sent to authorised recyclers and mining of metals should not be performed if the dismantler does not have the authorisation and required expertise to do so.
Dismantling of e-waste involves the following operations
- Manual Dismantling of e-waste using appropriate tools into different components and parts.
- Volume/Size reduction can also be carried out after the dismantling of e-waste parts made of steel, aluminium or plastic for equipment like refrigerators, washing machines, CRT monitors etc., for ease of transportation.
Having facilities as per the Central Pollution Control Board guidelines and authorisation and consent from the concerned State Pollution Control Board (SPCB) is necessary for any dismantling unit to operate in the country. In this article, we would try to discuss all necessary authorisation and licenses needed for dismantling of e-waste.
Authorisation Process for the dismantling of e-waste
The following licences and authorisation are needed by a unit for the dismantling of e-waste.
Certificate of registration
The first step in obtaining authorisation is to apply for a certificate of registration issued by the District Industries Centre or any government agency authorised for the purpose.
Consent to Establish (CTE)
CTE for dismantling of e-waste is granted by the concerned State Pollution Control Board under the CTE for dismantlers will be issued subject to the production of the following documents
- Application Form
- Undertaking by the owner
- Site Plan along with a roadmap
- Detailed Project Report with details of emission, effluent, solid waste management plan, raw materials, finished products, manufacturing process including a list of machinery, the capital cost of the unit (land, building, and plant machinery),
- Proof of Possession/rent Agreement/ lease document (as applicable)
- Certificate of Registration
Authorisation by SPCB
Next step in the process of setting up a unit for the dismantling of e-waste involves obtaining authorisation from the SPCB for the dismantling of e-waste. The following documents are needed in this step
- Duly filled application
- CTE granted by the SPCB
- Certificate of registration issued by District Industries Centre
- Proof of installed capacity of plant and machinery issued by the District Industries Centre
- Process flow chart for dismantling E-waste.
- Details of Air Pollution Control Devices installed
- Details of Effluent treatment Plant installed.
- Membership and registration with authorised TSDF operator
- Power of Attorney/Authority letter
- Details of facilities and arrangements installed for dismantling e-waste and managing hazardous waste.
- Copy of Allotment Letter.
Consent to Operate
SPCB issues Consent to operate after CTE has been given to the unit for Dismantling of e-waste and all necessary parameters of pollution control mechanisms have been installed. A site inspection is carried out before issuing CTO after scrutiny. This can be a lengthy process as it involves many formalities and documents like
- Land-related documents (rent agreement, porcha, lease document, rent receipt etc.)
- Gross Capital Investment Certificate
- site plan with road map/route map
- A detailed report of the project along with details of emission, effluent, solid waste management plan, raw materials, finished products, and manufacturing process, including a list of machines.
- Copy of Consent to Establish (NOC) Certificate
- Test Reports for emission/effluent (done within the last year)
Premise specific requirements for dismantling
Fulfilling all legal requirements by E-waste dismantling unit can be a challenging task and proper guidance by experts in this field can make this process easier. Below are some measures that must be implemented to ensure a safe and proper dismantling of e-waste so that all the above licences and authorisations are issued without any hassle at the time of site inspection by the SPCB.
- Waterproofing the roof and porous surfaces along with appropriate spillage collection facilities.
- Maintain appropriate Space for dismantling and storage for dissembled spare parts.
- Appropriate containers for storage of batteries, capacitors containing PCBs (Polychlorinated biphenyls) or PCTs (Polychlorinated terphenyls).
- Adequate measures to handle hazardous waste like brominated flame retardants, lead, cadmium, mercury, plastic waste and hexavalent chromium compounds if dismantling parts contain these hazardous chemicals.
Post licencing Compliances to be followed by a dismantler
The SPCB will issue the CTO and the unit can start its operation of the dismantling of e-waste. However certain compliances need to be met by the dismantler mentioned in the NOC during the course of its operation. These compliances can be along the lines of the following safety measures like
- During the size reduction of dismantled items made of steel/aluminium/plastic parts, the dismantlers should have dust and noise controls. Dismantling of e-waste should be under enclosure for noise reduction to permissible limits.
- Directly usable components are sent to an authorised refurbisher while other parts to recyclers with a valid CTO.
- Dismantlers must not carry out shredding/ crushing/ fine grinding/wet grinding/ enrichment operations or separation of printed circuit board or the components attached with the circuit board through gravity/ magnetic/density/eddy current.
- While dismantling of e-waste, chemical leaching, heating or melting of the material is not permitted.
- Dismantler should have adequate facilities to dispose of bag filter residue securely.
- Dismantlers should not break CRTs. It should be sent to authorised e-waste recyclers. In case of refrigerators and air conditioners before dismantling the compressors, adequate measures should be implemented to recover coolant/refrigerant gases and compressor oils.
- Dismantler must not store dismantled circuit boards, CRTs, capacitors, batteries, capacitors containing PCBs (Polychlorinated biphenyls) or PCTs (Polychlorinated terphenyls) etc. in the open.
- The dismantled parts must be sent to authorised e-waste recyclers or recyclers having a valid consent to operate (CTO).
- The workers should use personal protective equipment such as goggles, masks, gloves, helmets, gumboots etc.
- Batteries, printed circuit boards (PCBs) of EEE, toner cartridges, plastic parts and external electrical Cables components must be removed from the end of life products and stored safely for transportation to recyclers.
- Dismantled and segregated plastic from e-waste is only given to registered plastic recyclers.
- Dismantler must maintain a record of dismantled e-waste and send it to an authorised recycler and produce this record for scrutiny by CPCB or SPCB when demanded. Dismantler must maintain record of each delivery received.
- Dismantler must not process any e-waste for recovery or refining of metals unless the unit has been authorised by the concerned SPCB as a recycler for refining and recovery of materials.
Licensing is one of the most crucial aspects to be handled before starting any business. Proper authorisation ensures smooth functioning of units especially when it comes to the recycling sector. Recent initiatives by many states under the ease of doing business have tried to streamline this process but in e-waste recycling is a complex issue with many environmental agencies guarding the whole sector like hawks, the process can become tedious and time-consuming. Working within the guidelines along with licencing and authorisation, an e-waste dismantling unit can turn into a profitable business because of the hidden value associated with it.
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