Toxic Materials Compliance

"Assume that the strictest laws are going to be enforced everywhere," Zigman says, "and it's going to make your life much easier." He recommends that CIOs appoint a coordinator to be responsible for an e-waste plan. Besides a written policy, which is required by the EPA, Zigman says, CIOs should perform due diligence on third-party vendors to ensure, for instance, that they can certify what happens to equipment once it is hauled away.

Also on the federal level, lawmakers involved with the Congressional E-Waste Working Group are pushing for a national recycling plan. And in February, the U.S. Postal Service launched an initiative to form partnerships with contractors to handle items disposed of in a nationwide e-waste recycling program for consumers and small businesses.

The E.U. directive requires that electrical and electronics equipment manufactured for distribution in E.U. nations after July 1 must be free of lead, mercury, cadmium, chromium and other specified toxins. (There are exemptions for certain medical and other devices.) Over time the directive will mean that electronics and electrical products globally will be more environmentally friendly, since manufacturers aren't likely to produce separate goods for distribution outside of the European Union, according to IT analysts.

Meanwhile, analyst Roger Kay, president of Endpoint Technologies Associates Inc., appeals to the conscience of those making decisions about recycling and equipment disposal. "From my perspective, there's no question about compliance. Not only is it illegal in many states to dump [e-waste], it's just the wrong thing to do," he says.