California Firms Receive Reminder on Downstream Due Diligence
By: Bobby Elliott

In another sign of the increasingly tight CRT glass market, regulators in California have asked registered e-scrap firms to exercise caution when planning to send glass beyond state lines.

"If your company is shipping CRTs or CRT glass out-of-state, you should understand the difference between a destination that remanufactures CRT glass and/or engages in lead smelting, and an intermediate facility," the Department of Toxic Substances Control (DTSC) wrote in a Dec. 10 advisory notice. "Most CRT processing facilities in other states are intermediate facilities. Your company bears responsibility under California law for material while it is at an intermediate facility, and until it reaches its final destination for recycling."

The notice urges recycling firms to "ask hard questions of out-of-state facilities in order to avoid potentially crippling liability for material mishandled downstream." It also references the costly clean-up of Dow Management's Yuma, Arizona CRT glass operation, which had received and stockpiled large quantities of glass from California and Washington. The company later went out of business, and California firms were required to retrieve glass sent to Dow and have it sent elsewhere for final processing.

"DTSC does not want to see such a scenario happen again — either for the sake of the environment or for the sake of California recyclers," DTSC's Rita Hypnarowski wrote in a follow-up email.

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