U.S. Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health
Page 2

Contents

Highlights...............................................i

Abbreviations ..................................... iii

Introduction......................................... 1

Methods ............................................... 1

Results .................................................. 3

Discussion .......................................... 10

Conclusions........................................ 12

Appendix............................................ 13

References.......................................... 17

Acknowledgements........................... 19

The employer is required to post a copy of this report for 30 days at or near the 

workplace(s) of affected employees. The employer must take steps to ensure 

that the posted report is not altered, defaced, or covered by other material.

The cover photo is a close-up image of sorbent tubes, which are used by the HHE 

Program to measure airborne exposures. This photo is an artistic representation that may 

not be related to this Health Hazard Evaluation. Photo by NIOSH.
Page i

We surveyed a randomly 

selected subset of e-scrap 

recycling facilities nationwide 

to characterize work processes, 

exposures, and controls. Despite 

multiple attempts to contact 

the facilities, of the 278 facilities 

contacted, only 47 responded. 

Many facilities reported that 

they had employee health and 

safety practices and controls in 

place.

Highlights of this Pilot Assessment 

The Health Hazard Evaluation Program established an interagency agreement with the U.S. 

Environmental Protection Agency to learn more about the e-scrap recycling industry. As part 

of this interagency agreement, we surveyed a randomly selected sample of e-scrap recycling 

facilities nationwide.

What We Did

● We developed a survey to learn about work processes, exposures, controls, and health 

and safety programs at e-scrap recycling facilities across the United States.

● We contacted 278 e-scrap recycling facilities between September 2012 and April 2013.

What We Found

● Forty-seven facilities completed the survey. 

The response rate was 17%.

● Surveyed facilities averaged 58 employees. 

● Most facilities had an industry certification.

● Surveyed facilities reported recycling a wide 

variety of electronics.

● The most common recycling processes 

were manual dismantling and sorting. Other 

processes included shredding, crushing, and 

automated separation.

● Most facilities reported having local exhaust 

or general ventilation. Some reported having 

environmental/ industrial hygiene monitoring 

and biomonitoring.

● Most facilities reported having a health and safety committee.

● Most facilities reported providing personal protective equipment for employees.

● Some facilities reported the use of compressed air for cleaning. This practice can lead 

to increased employee dust exposures.

● Some facilities allowed food and drinks in the production areas. This practice can lead 

to ingestion of contaminants.

What We Concluded

● E-scrap recycling has the potential for a wide variety of occupational exposures 

particularly because of the use of manual processes.

● On-site evaluations of e-scrap recyclers are needed to determine if reported work 

processes, practices, and controls are effective and meet current standards and guidelines.

● Educating the e-scrap recycling industry about adequate health and safety practices, 

specifically related to safe handling of metal dust, would help protect employee health. 

● This survey may not represent the U.S. e-scrap recycling industry because of the low 

response rate.
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Page iii

Abbreviations

CAER Coalition for American Electronics Recycling 

E-scrap Electronic waste

HEPA High-efficiency particulate air

ISO International Organization for Standardization

LEV Local exhaust ventilation

NAID National Association for Information Destruction® 

NIOSH National Institute for Occupational Safety and Health

OHSAS Occupational Health and Safety Advisory Services 

OSHA Occupational Safety and Health Administration

PPE Personal protective equipment 

R2 Responsible RecyclingTM 

RIOS Recycling Industry Operating Standard® 
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Page 1

Introduction

As of May 2014, 25 states had laws mandating electronic-scrap (e-scrap, also called 

e-waste) recycling. In 2012, the U.S. e-scrap recycling industry contributed approximately 

$20.6 billion to the U.S. economy, compared to less than $1 billion in 2002. In 2012, this 

industry sector employed more than 45,000 full-time employees, up from 6,000 employees 

in 2002 [ISRI 2014a]. 

Americans own almost 3 billion electronic products, including televisions, cell phones, 

computers, and peripherals (keyboards, scanners, faxes, etc.) [EPA 2007]. As new electronic 

products are developed and sold, obsolete or end-of-life products become e-scrap. This 

e-scrap amounted to about 2.3 million tons in 2007 with only 18% being recycled [EPA 2008]. 

In 2011, more than 4.4 million tons of used and end-of-life electronic devices were recycled 

[ISRI 2014a]. E-scrap contains more than 1,000 substances, many of which are hazardous 

[Wath et al. 2011], including heavy metals (lead, cadmium, mercury, beryllium, etc.), flame 

retardants, phthalates, and ozone depleting substances. The potential exists for worker 

exposure to these hazardous substances during recycling, but data are limited on the type and 

extent of exposures in developed countries [Tsydenova and Bengtsson 2011]. 

The rapid growth of the industry and the limited information about potential workplace health 

and safety hazards has revealed a need to learn more about the e-scrap recycling industry. To 

that end, the National Institute for Occupational Safety and Health (NIOSH) established an 

interagency agreement with the Environmental Protection Agency to characterize potential 

occupational exposures; evaluate work practices, programs, and policies; and provide 

recommendations to reduce worker exposures in e-scrap recycling facilities. The interagency 

agreement had two components: (1) to perform on-site health hazard evaluations at three 

e-scrap recycling facilities, and (2) to administer a survey to a randomly selected sample of 

e-scrap recycling facilities nationwide. This report discusses the results of the pilot survey. 

The results from the three workplace health hazard evaluations will be published separately.

Methods

Survey

We surveyed a randomly selected subset of e-scrap recycling facilities nationwide to 

characterize work processes, exposures, and controls. The survey developed by NIOSH 

and field tested by the contractor, Oak Ridge Associated Universities, is in Appendix A. 

The original survey included questions related to production quantities for each of the 

components processed but these questions were eliminated mid-way through the project due 

to the reluctance of respondents to provide this information. Additional changes included 

minor modifications to streamline the wording of some questions. The survey asked about:

● Certification(s)

● Number of employees

● Major components processed
Page 2

● Processes performed 

● Personal protective equipment (PPE) used

● Type of general ventilation, engineering, and administrative controls

● Medical surveillance and industrial hygiene monitoring

Facilities for the Survey

NIOSH contracted with Oak Ridge Associated Universities to contact e-scrap recycling 

companies, identify appropriate contact personnel at each facility to complete the survey, 

administer or provide the survey to that person(s), and provide data securely to NIOSH. The 

period of performance of this contract was September 14, 2012, to April 15, 2013. 

NIOSH obtained a list of more than 1,300 e-scrap recycling companies that are subscribers 

to an industry magazine, and then selected 300 facilities using Research Randomizer (http://

www.randomizer.org/) with a goal to obtain 100 responses. NIOSH personnel initially 

contacted these 300 facilities to see if they were still in operation. Of these, 178 facilities 

were still operating and the name and contact information was successfully used by the 

NIOSH contractor for followup. Eleven of these facilities with multiple locations referred 

19 sister facilities to provide a response to the survey. Because of the low response rate from 

those 197 facilities, the NIOSH contractor asked NIOSH to provide contact information for 

an additional 100 facilities and these were also randomly selected from the list of magazine 

subscribers. NIOSH did not call these 100 additional facilities prior to giving their contact 

information to the contractor. Of these, 81 companies were still operating.

Following a script, the NIOSH contractor made 868 contacts (phone calls or e-mails) to 278

facilities in 43 states. The script contained information about the overall project, the survey, 

and NIOSH. After initial contact with the facility by the contractor, NIOSH sent a letter to 

the main facility contact to endorse the survey. Most of the facility contacts preferred to 

see the survey before agreeing to participate. They also preferred to complete the survey 

independently rather than during a scheduled phone call as initially planned. E-mail was the 

preferred method of correspondence for most representatives at the facilities contacted.

To promote the survey and increase visibility, information about the survey was 

posted on the NIOSH health hazard evaluation webpage, Facebook©, NIOSH 

monthly e-newsletter, Occupational Health & Safety magazine (http://ohsonline.com/

articles/2013/01/11/niosh-program-evaluating-controls.aspx), and E-scrap News, a 

leading electronic waste recycling newsletter.

Data Management and Analysis

Password-protected electronic files were created to contain the survey information. Each 

facility was assigned a unique identifier, and a separate file containing all survey responses 

but without facility identifiers was created. All data were stored securely in Microsoft Excel® 

files, accessible only by NIOSH staff. 
Page 3

Results

Nineteen companies, representing 47 facilities in 28 states completed the survey for a response 

rate of 17%. Details of contacts and contact attempts made are summarized in Table 1.

Table 1. Survey outcomes

Number of facilities

Survey responses received from original facilities contacted 30

Survey responses received from facilities referred within the same company 19

Facilities initially agreed to complete the survey but later refused 11

Made contact, determined qualified personnel, but no response 46

Refused survey 40

No response, and follow-up was unsuccessful* 132

Total 278

*Five repeated attempts were made to each facility.

Certification of E-scrap Recycling Facilities

Six different certifications were reported: e-Stewards®, Responsible RecyclingTM (R2), 

Occupational Health and Safety Advisory Services (OHSAS) 18001, International 

Organization for Standardization (ISO) 14001, Recycling Industry Operating Standard® 

(RIOS), and National Association for Information Destruction® (NAID) (Table 2). Only 

two facilities had no certifications, 7 facilities had one certification, and 38 facilities had two 

or more certifications. E-Stewards and R2 are specific to the e-scrap recycling industry and 

address export, landfilling, and incineration; use of prison labor; data security; and employee 

safety and health, among other things. OHSAS 18001 is an international occupational health 

and safety management system, and ISO 14001 is an environmental management system. 

RIOS is the scrap recycling industry’s (including e-scrap) integrated management system 

standard for quality, environment, and health and safety. It includes elements of ISO 9001, 

ISO 14001, and OHSAS 18001. NAID verifies the qualifications of certified information 

destruction providers through an audit program.

Table 2. Certifications of 47 surveyed facilities 

Certifications Number of facilities

R2 38

ISO 14000 38

e-Stewards® 32

OHSAS 18001 18

RIOS® 3

NAID® 3

None 2
Page 4

Workforce Size 

The size and composition of the workforce at the surveyed facilities is shown in Table 3. 

The surveyed facilities averaged 58 employees, with a median of 60 employees; most had 

between 70 and 79 employees.

Table 3. Number of employees at the 47 facilities by type 

Number of facilities

Number of employees All employees Production employees Office employees 

1 to 9 2 4 20

10 to 19 5 4 22

20 to 29 5 7 0

30 to 39 4 4 2

40 to 49 2 3 1

50 to 59 1 8 0

60 to 69 6 14 0

70 to 79 15 0 0

80 to 89 0 1 1

90 to 99 3 1 1

≥ 100 4 1 0

Major Components Processed

All surveyed facilities accepted printed circuit boards, and most accepted switches, batteries, 

cell phones, fluorescent lamps and bulbs, cathode ray tubes, desktop bases and laptops, 

computer peripherals, liquid crystal displays, printers, fax machines, and audio/video 

equipment (Table 4). Other components accepted included computer hardware servers, power 

cords, kitchen appliances, electrical cords, chips, refrigeration equipment, integrated circuits, 

and silicon on tape. All companies had at least one type of component that they accepted but 

did not process or recycle onsite. The most common item sent out for further processing was 

fluorescent lamps and bulbs.
Page 5

Table 4. Components accepted and processed at the 47 facilities

Number of facilities

Not accepted Accepted Processed Sent out for 

processing

Batteries 5 42 24 18

Cell phones 4 43 37 6

Cathode ray tubes 5 42 26 16

Desktop bases and laptops 1 46 40 6

Computer peripherals 1 46 39 7

Liquid crystal displays 2 45 39 6

Fluorescent lamps and bulbs 6 41 12 29

Printed circuit boards 0 47 42 5

Switches 6 41 40 1

Printers 1 46 41 5

FAX/video/radio/music players 1 46 40 6

Processes Performed

Disassembly was the main process performed at 45 of the 47 surveyed facilities, 

followed by 37 facilities that performed separation, 28 that performed refurbishing, 18 

that performed plastic processing, and 2 that performed metallurgical processing. The 

types of disassembly are listed in Table 5; manual dismantling was the most common. 

The methods of separation performed are listed in Table 6; manual sorting and magnetic 

separation were the most common.

Table 5. Types of disassembly performed at the 47 facilities

Number of facilities

Manual dismantling 40

Shredding 29

Automated crushing 20

Manual crushing 6

Table 6. Methods of separation performed

Method Number of facilities/ 

total facilities responding

Manual sorting* 22/25

Magnetic separation 19/47

Eddy current separation 5/47

Gravity separation 1/47

*Only 25 facilities responded to this question because this 

question was added midway through the project.
Page 6

Two surveyed facilities performed pyro-metallurgical processing that uses heat to extract 

metals from e-scrap. No facility performed hydro- or bio-metallurgical processing, 

techniques that use biotechnology (microorganisms) to extract metals from e-scrap. No 

surveyed facility performed depolymerization (i.e., the process of converting a polymer 

into a monomer or a mixture of monomers) or incinerated plastics. Some facilities reported 

baling plastics or collecting and separating plastics for subsequent recycling by downstream 

processors, although this question was not specifically asked. Some facilities reported 

reselling usable equipment, although this question was not specifically asked.

Exposure Controls

Ventilation

Most surveyed facilities had separate ventilation systems for office and production areas, but 

only 19 facilities had controlled supply and exhaust air flow into the production area, and 

seven facilities provided conditioned (heated and/or cooled) air in the processing areas (Table 

7). This suggests that most facilities relied on natural ventilation in production areas.

Table 7. Types of general ventilation system in the 47 facilities

Number of 

facilities

Conditioned air in the processing areas 7

Controlled supply and exhaust air flow into 19

work areas

Separate ventilation for office areas 45

Types of Engineering Controls

Of the surveyed facilities, 33 used local exhaust ventilation (LEV) system(s) (Table 8). Some 

LEV systems recirculated this air back into the room after passing it through high efficiency 

particulate air (HEPA) filters, and some did not.

Table 8. Local exhaust ventilation systems in the 47 facilities

Number of 

facilities

LEV ducted to the outside of the building 8

LEV filtered and ducted back into the room with a 16

HEPA filter

LEV filtered and ducted back into the room with a 4

non-HEPA filter

Chemical fume hoods 2

Ventilated enclosures – Other 3
Page 7

Administrative Controls

Forty-four facilities reported having a safety and health committee with a nonmanagement participant. Thirty-eight facilities had a dedicated safety and health 

employee(s). Forty-five facilities performed environmental/industrial hygiene sampling 

at least annually and performed housekeeping on a regular basis. No surveyed facilities 

allowed smoking in the production areas, but 13 allowed eating and drinking. All 

surveyed facilities reported having spill control and chemical storage policies and 

procedures, and formal safety and health training for employees. Thirty-nine surveyed 

facilities reported using HEPA-filtered vacuums for clean-up. Three facilities used 

compressed air during clean-up. Twenty of the surveyed facilities reported some medical 

surveillance. The type of medical surveillance varied (Table 9), with audiometry being 

reported most frequently. Some facilities noted that chest x-rays were only performed for 

some production employees at the discretion of the company physician.

Table 9. Medical surveillance performed at the 47 facilities

Number of facilities Frequency

Blood lead levels 22 22 Pre-placement

5 Annual

4 Bi annual

Blood cadmium levels 3 3 Pre-placement

3 Annual

Urine cadmium levels 5 5 Pre-placement

3 Annual

2 Bi annual

Urine mercury levels 4 4 Pre-placement

3 Annual

1 Bi annual

Beryllium lymphocyte proliferation testing 1 1 Pre-placement

1 Every 3 years

Examination by doctor or other licensed health care 

professional

24 24 Pre-placement

22 Annual

Spirometry 9 9 Pre-placement

5 Annual

4 Bi annual

Chest x-ray* 20 18 Pre-placement

5 Annual

13 Every 3 years

Audiometry 31 31 Annual

*Some facilities noted that x-rays were only done at the discretion of the physician.
Page 8

Over half of surveyed facilities supplied production employees with coveralls or uniforms 

that were laundered by the company (Table 10). One facility had employees wash their 

uniforms at home. Over half of the surveyed facilities provided an area for employees to 

change clothes and shower. Although not specifically asked, some facilities commented that 

uniforms were only provided to certain production employees and 17 facilities commented 

that a third party laundered the uniforms.

Table 10. Uniforms provided by employer at the 47 facilities

Uniform administration Number of 

facilities

Supply coveralls/uniforms at the worksite 28

Employees take coveralls/uniforms home to be 

laundered

1

Have facilities to change clothes and shower 27

Facilities with more than 50 employees appeared to be more likely to have administrative 

controls such as biomonitoring and environmental/industrial hygiene sampling, and provide 

coveralls/uniforms at the worksite (Table 11).

Table 11. Comparison of health and safety controls by facility size at the 47 facilities

Control Number of employees (Number of facilities 

with that number of employees)

> 50 (28) < 50 (19) All sizes (47)

Controlled supply and exhaust air flow into the 

work area (%)

39 42 40

HEPA filtered vacuums used for clean-up (%) 89 74 83

Environmental/industrial hygiene sampling and 

monitoring performed on a regular basis 

(at least annually) (%)

100 89 96

Blood lead level monitoring (%) 57 32 47

Coveralls/uniforms supplied at the worksite (%) 71 42 60

Have facilities for employees to change clothes and 

shower (%)

64 47 57

Personal Protective Equipment

Personal protective equipment use is shown in Tables 12 and 13. Most surveyed facilities 

required the use of some PPE (gloves, eye protection, hearing protection, or steel-toed boots) 

during certain tasks. Gloves were required for most employees with the exception of those 

performing refurbishing (Table 13). Where respiratory protection was used, most respondents 

reported using filtering facepiece respirators, but some reported using half- or full face 

elastomeric respirators. Although not specifically asked, 13 facilities reported doing industrial 

hygiene sampling to determine if respirators and hearing protection was needed.
Page 9

Table 12. Personal protective equipment use by dismantling process 

Type of PPE Manual

dismantling

n = 40

Shredding

n = 29

Automated

crushing

n = 20

Manual

crushing

n = 6

Filtering facepiece* Required 15 16 9 3

Voluntary 16 9 11 2

Half- or full face 

elastomeric*

Required 1 12 0 1

Voluntary 0 1 0 0

Gloves Required 40 24 20 6

Voluntary 0 4 0 0

Eye protection Required 37 24 16 6

Voluntary 1 0 0 0

Hearing protection Required 29 28 17 4

Voluntary 9 0 3 2

Steel-toed boots Required 34 24 14 4

Voluntary 4 0 2 2

*NIOSH-approved respirator

Table 13. Personal protective equipment use, by separation, plastic, and refurbishing processes

Type of PPE Manual

sorting

n = 22

Magnetic

separation

n = 19

Eddy current

separation

n = 5

Plastic

processing

n = 18

Refurbish

n = 28

Filtering 

facepiece*

Required 0 5 0 0 0

Voluntary 8 3 2 2 8

Half- or full face 

elastomeric*

Required 0 1 1 0 0

Voluntary 4 0 0 0 0

Gloves Required 20 19 5 17 7

Voluntary 1 0 0 0 7

Eye protection Required 16 19 5 18 8

Voluntary 1 0 0 0 0

Hearing 

protection

Required 5 19 5 18 1

Voluntary 14 0 0 0 11

Steel-toed boots Required 16 18 5 18 5

Voluntary 1 1 0 0 2

*NIOSH approved respirator

Of the 31 facilities that reported using respirators in any process, all reported that they had 

written respiratory protection programs and provided respirator training to employees. 

However, 23 of the 31 facilities performed medical clearance and fit testing. Of the 

facilities that did not perform medical clearance and fit testing, four facilities required some 

employees to wear a respirator.
Page 10

Discussion 

We conducted a pilot survey to characterize occupational health and safety practices in the 

U.S. e-scrap recycling industry. Other surveys of the U.S. e-scrap recycling industry include 

one published in 2011 by the International Data Corporation [ISRI 2014b] and another 

published in 2013 by the Coalition for American Electronics Recycling (CAER) [American 

Recycling 2014]. The International Data Corporation survey documented company size 

and other business information from 103 facilities but did not include questions related to 

workplace health and safety. The CAER survey included 21 CAER member companies 

representing 89 facilities. The surveyed facilities averaged 205 employees (median of 

100 employees). The CAER survey reported that 45% of employees were involved in 

demanufacturing, 21% in asset recovery and disposition functions, and 18% in shredding 

operations [American Recycling 2014]. Asset recovery and disposition functions were 

defined as certified data destruction and disposition of assets where the recycler has 

the capability to record make, model, and serial number, and in some cases engages in 

refurbishment of equipment for resale.

In our survey, several facilities reported having general ventilation and local exhaust 

ventilation; some reported filtering and then recirculating exhaust air back into the room. 

We do not have enough information to know if the LEV systems were used in processes that 

may be producing potentially contaminated air. If this was the case for some of the LEV 

systems, the Occupational Safety and Health Administration (OSHA) prohibits recirculation 

of air containing metals such as lead through non-HEPA filters (29 CFR 1910.1025). The 

recirculation of process air into the work environment of highly hazardous substances (as 

defined by the OSHA hazard communication standard) requires both an effective cleaning 

device (filtration) and a continuous monitoring device that is capable of detecting a 

concentration as low as 10% of the acceptable level in the discharge duct [ANSI/AIHA 2007].

The most common type of medical surveillance reported was audiometry, followed by 

measuring blood lead levels. Audiometry and blood lead level tests are good practices for 

an e-scrap recycling facility given that lead and noise are common hazards in this industry 

[NIOSH 2009]. It was encouraging to see that all 22 facilities that reported blood lead 

monitoring had a pre-placement assessment of the employees. However, it is unclear why 

only five facilities followed their employees annually and four bi-annually. We could not 

determine from this brief survey whether blood lead monitoring met current recommended 

practices and whether all potentially exposed employees were included or just those thought 

to have the greatest potential for exposure to lead (e.g., those who handled cathode ray tube 

glass). It is important to include all employees potentially exposed to lead in the medical 

surveillance program, even those employees not directly exposed to lead contaminated 

air [Kosnett 2007]. Lead contamination on surfaces outside of the production area and 

contamination of surfaces in common areas such as breakrooms can result in ingestion of 

lead which contributes to the overall exposure of all affected employees. 
Page 11

Many facilities provided uniforms and facilities to change clothes and shower before 

leaving work, but one facility commented that they allowed employees to launder their 

work uniforms at home. This practice may provide a route of take-home exposure to family 

members. OSHA requires uniforms and showers for employees exposed to metals like lead 

and cadmium above the occupational exposure limit. However, it is good practice to provide 

uniforms, laundering, and showers to all employees potentially exposed to these substances 

[Kosnett 2007]. Uniforms and showers are among the most effective workplace measures in 

preventing take-home exposures [NIOSH 1995]. Current OSHA occupational exposure limits 

for lead are outdated; more recent information suggests that health effects can be experienced 

by employees at much lower levels. 

Current occupational exposures limits may prevent overt symptoms of lead poisoning, but 

do not protect workers from lead’s contributions to conditions such as hypertension, renal 

dysfunction, reproductive, and cognitive effects [Schwartz and Hu 2007; Schwartz and 

Stewart 2007; Brown-Williams et al. 2009; IOM 2012]. Generally, acute lead poisoning 

with symptoms has been documented in persons having BLLs above 70 μg/dL. These blood 

lead levels are rare today in the United States, largely as a result of workplace controls put 

in place to comply with current occupational exposure limits. When present, acute lead 

poisoning can cause myriad adverse health effects including abdominal pain, hemolytic 

anemia, and neuropathy. In very rare cases lead poisoning has progressed to encephalopathy 

and coma [Moline and Landrigan 2005]. People with chronic lead poisoning, which is more 

likely at current occupational exposure levels, may not have symptoms or they may have 

nonspecific symptoms that may not be recognized as being associated with lead exposure. 

These symptoms include headache, joint and muscle aches, weakness, fatigue, irritability, 

depression, constipation, anorexia, and abdominal discomfort [Moline and Landrigan 2005].

Some facilities allowed food and drinks in the production area, a practice that can lead to 

ingestion of hazardous substances from contaminated hands and food and drink surfaces. 

Some facilities reported using compressed air for cleaning. It was not clear from the 

survey responses if the compressed air was used for cleaning clothing, equipment, or both. 

Regardless, this practice can potentially result in contaminants entering the employees’ 

breathing zone, as well as spreading contamination throughout the facility. Noise from 

compressors used to provide compressed air for cleaning can contribute to hearing loss if 

employees do not use appropriate hearing protection. Cleaning with compressed air can also 

dislodge particles that could enter eyes or abrade skin. Wet mopping and vacuuming with 

HEPA filters are recommended cleaning practices.

Although a high percentage of surveyed facilities used PPE and performed environmental/

industrial hygiene monitoring, this survey did not evaluate the effectiveness of these 

programs. We do not know to what extent PPE use was enforced and how many employees 

participated in any personal exposure monitoring for lead or other contaminants as prescribed 

by OSHA [OSHA 2014]. The four facilities that required the use of respirators but did 

not provide employees with medical clearance or fit testing were not following the OSHA

respiratory protection standard [29 CFR 1910.134].
Page 12

This survey had limitations. The main limitation was the low response rate. At the beginning 

of the pilot survey, we did not provide the targeted facilities with preliminary information 

about NIOSH, or information about the purpose of the survey prior to making the initial 

phone call. Because many facilities were not familiar with NIOSH, on the initial call, they 

misidentified our surveyor as being from a competitor or market research firm. Once we 

began sending an introductory letter to facilities prior to the initial call, informing them of 

the purpose of the survey and providing them information about NIOSH, our participation 

improved. Initial respondents were reluctant to share information about the quantities of 

materials processed; this line of inquiry was later dropped from the survey, which also 

improved the survey participation. Finally, smaller facilities who chose not to participate 

often reported that our survey questions did not match their own activities (e.g., most 

facilities with fewer than five employees did not dismantle electronics, but sorted items and 

shipped them to other facilities for processing). 

Although our results may not be generalizable to all U.S. e-scrap recycling facilities, they 

are informative regarding existing health and safety programs in the industry. Focusing 

on processing of cathode ray tubes and liquid crystal displays (two major electronic items 

that are recycled) would be desirable in future surveys. Additionally, further information 

is needed on the specific demographics of the workforce (e.g., race and ethnicity), and the 

health and safety needs of the industry. Moreover, onsite workplace evaluations would help 

to determine if programs and controls reported by e-scrap managers are actually meeting 

current standards and guidelines.

Conclusions

This pilot survey of the U.S. e-scrap recycling industry provided information on health 

and safety programs and practices at 47 facilities among a rapidly increasing and changing 

industry. To expand our knowledge and to respond to the expectations of growing health 

and safety needs in this industry, resources need to be directed to this industry to capture 

more widely the occupational hazards, health consequences, specific processes, and 

exposures of concern. Efforts to evaluate, support, and promote good health and safety 

practices in the growing and dynamic e-scrap recycling industry are needed to prevent 

occupational illnesses and injuries.
Page 13

Appendix A: Facility Questionnaire

Company Information Date administered: Date confirmed:

Company Name

Street Address

Address Line2

City, State, Zip 

Phone Number

Website Address

Certified under _________ E-stewards __________ Responsible recycling practices (R2)

_________ Other (specify) ______________________ _______None

Company Technical Contact

Name

Title

Email Address

Phone Number

Background (IH, Safety, etc.)

Workforce Numbers at this Facility

# Total workers in facility 2011 or 2012

# Production workers

# Office-only workers

Major Components Processed

Y/N

Type Comments

Batteries (please specify: Li-ion; Ni-Cd; NiMH, 

lead-acid, Silver oxide, etc.)

Cell phones 

CRT (cathode ray tube) 

Desktop bases & laptops

Computer peripherals (mice, keyboards, etc.)

Liquid crystal displays (LCDs)

Fluorescent lamps/bulbs

Printed circuit boards

Switches

Printers

Fax machines, radios, video/DVD/music 

players, etc.

Other:
Page 14Processes performed and PPE used Processes Y/N NIOSH-approved Respirator

A = Filtering facepieceB = Half or full-face elastomericC = Other (specify)N = Not usedR/V = Required or Voluntary

Gloves Eye/face Hearing 

Protection

Steel-Toed 

Boots

A/B/C/N (R/V) Y/N R/V Y/N R/V Y/N R/V Y/N R/V

Disassembly ---- Manual dismantling- Manual crushing/pulverizing/etc. - Automated crushing/ pulverizing/etc. - Shredding- Other (please specify)Separation ---- Magnetic separation- Eddy current separation - Gravity separation- Manual sorting- Other (please specify)Metallurgical processing ---- Hydro-metallurgical - Pyro-metallurgical - Bio-metallurgical Plastic processing ---

- Depolymerization- Incineration- Other (please specify)

RefurbishingOther (Please specify)
Page 15

Types of General Ventilation and Administrative Controls (Check all that apply)

Y/N

General ventilation and administrative controls

a. Is the air conditioned in the processing areas?

b. Is there controlled supply and exhaust air flow into the work area? 

Is there separate ventilation for office areas?

Are HEPA filtered vacuums used for clean-up?

Is compressed air used during clean-up?

Do you have documented spill control and storage policies and procedures?

Is formal health and safety training provided to employees?

Is environmental/industrial hygiene sampling and monitoring performed on a regular basis 

(at least annually)?

Is medical monitoring performed on a regular basis (at least annually)?

Are there dedicated health and safety employee(s)?

Any Comments: 

Types of Engineering Controls (Check all that apply and list process/areas)

Y/N List for what processes/areas

Local exhaust ventilation (LEV) 

a. LEV ducted to the outside of the building

b. LEV filtered and ducted back into the room with a 

HEPA filter

c. LEV filtered and ducted back into the room with a 

non-HEPA filter

Chemical fume hoods

Ventilated enclosures – Other (Describe) 

Any Comments: 
Page 16

Medical Surveillance (Check all that apply and write in frequency)

Y/N

Does your facility perform any of the following for 

employees who handle e-scrap? 

---- Frequency – how often?

Pre-placement Periodic

Biological monitoring – if yes, please check all that 

apply

---- ------- -------

- Blood lead levels

- Blood cadmium levels

- Urine cadmium levels

- Urine mercury levels

- Beryllium LPT

- Other: specify

Physical examinations – if yes, please check all that 

apply

---- ------- -------

- Examination by doctor or other licensed health 

care professional

- Spirometry (lung function testing)

- Chest x-ray

- Other (specify):

Audiometry (hearing tests)

Other (Please specify):

Additional Administrative Controls (Check all that apply)

Y/N

If respirators are used, do you provide the following 

a. Medical clearance

b. Training 

c. Fit testing

d. Written respiratory protection program

Are coveralls/uniforms supplied at the worksite?

Are coveralls/uniforms taken home by the workers to be laundered?

Do you have facilities for employees to change clothes and shower?

Is housekeeping performed on a regular basis?

Is food & drink allowed in process areas?

Is smoking allowed in process areas?

Do you have a safety and health committee at this facility?

If yes, are non-management employees part of the committee?

Would you be willing to participate in a possible future worksite evaluation with NIOSH?

Thank you so much for participating in this NIOSH evaluation. We will scan and email a 

copy of this questionnaire to you to review for accuracy. We will also send you via email a 

copy of the final report from this effort once it is completed. If you have further questions, 

please contact NIOSH project officers.
Page 17

References

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Electronics Recycling - membership survey and jobs study of the potential of the U.S. 

electronics recycling industry. Final Report I January 2013. [http://www.americanerecycling.

org/images/CAER_Jobs_Study_Report_-_January_2013.pdf]. Date accessed: June 2014.

ANSI/AIHA [2007]. American National Standard for recirculation of air from industrial 

process exhaust systems. ANSI/AIHA Z9.7-2007. Fairfax, VA: American Industrial 

Hygiene Association.

Brown-Williams H, Lichterman J, Kosnett M [2009]. Indecent exposure: lead puts workers 

and families at risk. Health Research in Action, University of California, Berkeley. 

Perspectives 4(1). [http://www.healthresearchforaction.org/sites/default/files/PDF_

PERSPECTIVES_IndecentExp%20FNL_0.pdf]. Date accessed: June 2014.

CFR. Code of Federal Regulations. Washington, DC: U.S. Government Printing Office, 

Office of the Federal Register.

EPA [2007]. Fact sheet: management of electronic waste in the United States. U.S. 

Environmental Protection Agency, Washington, DC. EPA530-F-08-014. 

EPA [2008]. Electronics waste management in the United States Approach 1. Office of Solid 

Waste, U.S. Environmental Protection Agency, Washington, DC. EPA530-R-08-009. 

IOM [2012]. Potential health risks from recurrent lead exposure of DOD firing range 

personnel. Washington, DC: National Academies Press.

ISRI [2014a]. The scrap recycling industry: electronics. [http://www.isri.org/ISRI/_

Government_Relations/Electronics_Recycling/ISRI/_Government_Relations/Electronics_

Recycling.aspx?hkey=5c8e7627-8f5c-423a-a1fa-d10228866286]. Date accessed: June 2014.

ISRI [2014b]. Survey – Inside the U.S. electronics recycling industry. [http://www.isri.org/

CMDownload.aspx?ContentKey=b4870939-31cd-4110-9ce1-53ed3bc3a8bf&ContentItemKe

y=b02f4142-da79-44ba-bab4-4a631c06b4a3]. Date accessed: June 2014.

Kosnett MJ, Wedeen RP, Rothenberg SJ, Hipkins KL, Materna BL, Schwartz BS, Hu H, 

Woolf A [2007]. Recommendations for medical management of adult blood lead exposure. 

Environ Health Perspect 115(3):463–471.

Moline JM, Landrigan PJ [2005]. Lead. In: Rosenstock L, Cullen MR, Brodkin CA, 

Redlich CA, eds. Textbook of clinical occupational and environmental medicine. 2nd ed. 

Philadelphia, PA: Elsevier Saunders, pp. 967–979.
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NIOSH [1995]. Report to Congress on the workers’ home contamination study conducted 

under the Workers’ Family Protection Act (29 U.S.C. 671a). Cincinnati, OH: U.S. 

Department of Health and Human Services, Centers for Disease Control and Prevention, 

National Institute for Occupational Safety and Health, DHHS (NIOSH) Publication No. 95-

123. [http://www.cdc.gov/niosh/docs/95-123/]. Date accessed: June 2014. 

NIOSH [2009]. Health hazard evaluation report: exposure to hazardous metals during 

electronics recycling at four UNICOR facilities. By Page E, Sylvain D. Cincinnati, 

OH: U.S. Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health, NIOSH HHE Report 

No. 2008-0055-3098.

OSHA [2014]. 1910.1025 App B: employee standard summary. [https://www.osha.gov/

pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10032]. Date 

accessed: June 2014.

Schwartz BS, Hu H [2007]. Adult lead exposure: time for change. Environ Health Perspect 

115(3):451–454. 

Schwartz BS, Stewart WF [2007]. Lead and cognitive function in adults: a question and 

answers approach to a review of the evidence for cause, treatment, and prevention. Int Rev 

Psychiatry 19(6):671–692.

Tsydenova O, Bengtsson M [2011]. Chemical hazards associated with treatment of waste 

electrical and electronic equipment. Waste Manage 31(1):45–48.

Wath SB, Dutt PS, Chakrabarti T [2011]. E-waste scenario in India, its management and 

implications. Environ Monit Assess 172(1–4):249–262. 
Page 19

The Health Hazard Evaluation Program investigates possible health hazards in the workplace 

under the authority of the Occupational Safety and Health Act of 1970 (29 U.S.C. § 669(a)

(6)). The Health Hazard Evaluation Program also provides, upon request, technical assistance 

to federal, state, and local agencies to investigate occupational health hazards and to prevent 

occupational disease or injury. Regulations guiding the Program can be found in Title 42, Code 

of Federal Regulations, Part 85; Requests for Health Hazard Evaluations (42 CFR Part 85).

Disclaimer

The recommendations in this report are made on the basis of the findings at the workplace 

evaluated and may not be applicable to other workplaces.

Mention of any company or product in this report does not constitute endorsement by NIOSH.

Citations to Web sites external to NIOSH do not constitute NIOSH endorsement of the 

sponsoring organizations or their programs or products. NIOSH is not responsible for the 

content of these Web sites. All Web addresses referenced in this document were accessible as of 

the publication date.

Acknowledgments

Contract Support: Oak Ridge Associated Universities

Desktop Publisher: Shawna Watts 

Editor: Ellen Galloway 

Industrial Hygiene Assistance: Lilia Chen and Brian Curwin

Industry Contacts: E-Scrap Newsletter

This work was supported by funding from the United States Environmental Protection Agency 

(Interagency Agreement No: DW-75-92357701–0; CDC/NIOSH IAA No: 12-NS12-11) and 

the National Institute for Occupational Safety and Health, Centers for Disease Control and 

Prevention.

Availability of Report

This report is not copyrighted and may be freely reproduced.

Recommended citation for this report:

NIOSH [2014]. Health hazard evaluation report: a pilot assessment of occupational 

health hazards in the U.S. electronic scrap recycling industry. By Ceballos D, Gong 

W, Page E. Cincinnati, OH: U.S. Department of Health and Human Services, Centers 

for Disease Control and Prevention, National Institute for Occupational Safety and 

Health.
Delivering on the Nation’s promise:

Safety and health at work for all people through research and prevention

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