ELECTRONIC WASTE

Actions Needed to 

Provide Assurance 

That Used Federal 

Electronics Are 

Disposed of in an 

Environmentally 

Responsible Manner

Report to the Ranking Member, 

Committee on Oversight and 

Government Reform, House of 

Representatives

February 2012

GAO-12-74

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-74, a report to the

Ranking Member, Committee on Oversight 

and Government Reform, House of 

Representatives 

February 2012 

ELECTRONIC WASTE

Actions Needed to Provide Assurance That Used 

Federal Electronics Are Disposed of in an 

Environmentally Responsible Manner

Why GAO Did This Study

The Environmental Protection Agency 

(EPA) estimates that across the federal 

government 10,000 computers are 

discarded each week. Once these 

used electronics reach the end of their 

original useful lives, federal agencies 

have several options for disposing of 

them. Agencies generally can donate 

their reusable electronics to schools; 

give them to a recycler; exchange 

them with other federal, state, or local 

agencies; or sell them through selected 

public auctions, including auctions 

sponsored by the General Services 

Administration (GSA). As the world’s 

largest purchaser of information 

technology, the U.S. government, 

through its disposition practices, has 

substantial leverage to influence 

domestic recycling and disposal 

practices. GAO was asked to examine 

(1) key initiatives aimed at improving 

the management of used federal 

electronics and (2) improvements 

resulting from these initiatives and 

challenges that impede progress, if 

any. To do this, GAO evaluated federal 

guidance and policy, as well as 

guidance and initiatives at five selected 

agencies. GAO selected agencies 

based on, among other things, the 

amount of electronics purchased. 

What GAO Recommends

GAO recommends, among other 

things, that the White House Council 

on Environmental Quality, the Office of 

Management and Budget, and GSA 

take actions to require consistent 

tracking and reporting of used 

electronics and ensure appropriate

management of electronics sold at 

auction. Each agency concurred with 

GAO’s recommendations but, in some 

instances, proposed alternatives for 

executing the recommendations. 

What GAO Found

Over the past decade, the executive branch has taken steps to improve the 

management of used federal electronics. Notably, in 2003, EPA helped to pilot

the Federal Electronics Challenge (FEC)—a voluntary partnership program that 

encourages federal facilities and agencies to purchase environmentally friendly 

electronic products, reduce the impacts of these products during their use, and 

manage used electronics in an environmentally safe way. EPA also led an effort 

and provided initial funding to develop third-party certification so that electronics 

recyclers could show that they are voluntarily adhering to an adopted set of best 

practices for environmental protection, worker health and safety, and security 

practices. In 2006, GSA issued its Personal Property Disposal Guide to assist 

agencies in understanding the hierarchy for disposing of excess personal 

property, including used electronic products: reutilization, donation, sale, and 

abandonment or destruction. In 2007 and 2009, executive orders were issued 

that, among other things, established improvement goals and directed agencies 

to develop and implement improvement plans for the management of used 

electronics. The Office of Management and Budget, the Council on 

Environmental Quality, and the Office of the Federal Environmental Executive 

each play important roles in providing leadership, oversight, and guidance to 

assist federal agencies with implementing the requirements of these executive 

orders. To lay the groundwork for enhancing the federal government’s 

management of used electronic products, an interagency task force issued the 

July 2011 National Strategy for Electronics Stewardship. The strategy, which

describes goals, action items, and projects, assigns primary responsibility for 

overseeing or carrying out most of the projects to either EPA or GSA. 

Federal agencies have made some progress to improve their management of 

used electronic products, as measured by greater participation in the FEC and an 

increase in certified electronics recyclers, but opportunities exist to expand their 

efforts. For instance, agency participation in the FEC represents only about onethird of the federal workforce. GAO identified challenges with the tracking and 

reporting on the disposition of federal electronic equipment. For the five agencies 

GAO reviewed (Departments of Defense, Energy, Education, and Housing and 

Urban Development and the National Aeronautics and Space Administration), 

data provided on the disposition of electronic products were inconsistent, which 

hampered GAO’s efforts to accurately assess the extent to which electronic 

products procured by federal agencies are disposed of in an environmentally 

sound manner. Challenges associated with clarifying agencies’ responsibility for 

used electronics sold through auctions also remain. Currently, neither the agency 

nor the auction entities are required to determine whether purchasers follow 

environmentally sound end-of-life practices. Not having controls over the ultimate 

disposition of electronics sold through these auctions creates opportunities for 

buyers to purchase federal electronics and export them to countries with less 

stringent environmental and health standards. Other challenges that may impede 

progress toward improving federal agencies’ management of used electronics 

include defining key terms such as “electronic product” and “environmentally 

sound practices,” as each agency uses its own definition of electronic products to 

report progress in implementing policies for electronics stewardship. 

View GAO-12-74

For more information, contact Frank Rusco at 

(202) 512-3841 or ruscof@gao.gov.
Page i GAO-12-74 Electronic Waste

Letter 1 

Background 4

Key Initiatives to Improve Federal Agencies’ Management of Used 

Electronic Products Have Been Launched over the Past 10 Years 6

The Management of Used Federal Electronics Has Improved and 

Opportunities Exist for Further Improvements, but Challenges 

Remain 14

Conclusions 25

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 27

Appendix I Objectives, Scope, and Methodology 31

Appendix II Comments from the Environmental Protection Agency 35

Appendix III GAO Contact and Staff Acknowledgments 37

Related GAO Products 38

Figure

Figure 1: Electronics Recycling Facilities Certified to the R2 or eStewards Standard, as of September 30, 2011 17

Contents
Page ii GAO-12-74 Electronic Waste

Abbreviations

CEQ Council on Environmental Quality

DLA Defense Logistics Agency

DOD Department of Defense

DOE Department of Energy

Education Department of Education

EPA Environmental Protection Agency

FEC Federal Electronics Challenge

FMR Federal Management Regulation

GSA General Services Administration

HUD Department of Housing and Urban Development

NASA National Aeronautics and Space Administration

OFEE Office of the Federal Environmental Executive

OMB Office of Management and Budget

R2 Responsible Recycling

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-74 Electronic Waste

United States Government Accountability Office 

Washington, DC 20548

February 17, 2012

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight 

and Government Reform

House of Representatives

Dear Mr. Cummings:

Rapid advances in technology have led to increasing sales of new 

electronic products, such as computers, computer monitors, televisions, 

and cell phones. These electronic products have created new business 

opportunities, new ways to communicate, and a new way of conducting 

business in both the private and public sectors. These advances, 

however, have also created new environmental challenges. As we have 

previously reported, electronic products may contain toxic substances—

such as cadmium, lead, and mercury—that can leach into soil or 

groundwater if improperly managed.1 As the world’s largest purchaser of 

information technology—spending about $80 billion in fiscal year 2010—

the U.S. government, through its disposition practices, has substantial 

leverage to influence domestic recycling, reuse, and disposal practices.

However, if the federal government’s used electronics are not 

appropriately managed, they could be disposed of in landfills domestically 

or exported to countries that have less strict environmental and safety 

protections.2

 

1

GAO, Electronic Waste: EPA Needs to Better Control Harmful U.S. Exports through 

Stronger Enforcement and More Comprehensive Regulation, 

Studies have shown that used electronic products exported 

from the United States to some countries are often dismantled under 

unsafe health conditions, using methods like acid baths to extract 

precious metals or open-air incineration. For example, we reported in 

2008 that, while some exports of used electronic products can be handled 

responsibly in countries with effective regulatory regimes and by 

companies with advanced technologies, some used electronic products 

GAO-08-1044 (Washington, 

D.C.: Aug. 28, 2008).

2

For purposes of this report, we refer to all federal electronic products that may be reused, 

recycled, disposed of, or discarded as “used.” Federal agencies also use other terms, 

such as excess or surplus. See FMR, Subchapter B-Personal Property, 41 C.F.R. §102-

35.20 (2011) 

 
 

Page 2 GAO-12-74 Electronic Waste

owned by federal agencies have been sent to developing countries where 

disposal practices are unsafe to workers and dangerous to the 

environment.3

Over the past decade, the executive branch has taken steps to improve 

the management of used federal electronics. For example, in 2007 and 

2009, executive orders were issued to strengthen federal agencies’ 

overall environmental management practices, including environmentally 

sound management of federal electronic products, from procurement 

through disposal—often referred to as electronics stewardship.4 Recently, 

we issued two reports that discussed elements of electronics stewardship 

outlined in the executive orders related to the use of federal electronics, 

including requirements to manage federal data centers in a more energyefficient manner and implement power management policies for 

computers.5

You requested that we review the status of federal initiatives to 

appropriately manage the disposition of used electronic products—that is, 

selling, donating, recycling, and disposing of federal electronics. Our 

objectives were to examine (1) key initiatives aimed at improving the 

management of used federal electronics and (2) improvements resulting 

from these initiatives and challenges that impede progress, if any.

To address the first objective, we reviewed guidance and documents 

regarding improvement initiatives led by the Environmental Protection 

Agency (EPA); analyzed the electronics stewardship requirements 

contained in the applicable executive orders and implementing 

instructions; the Federal Acquisition Regulation, which governs the 

process through which the federal government acquires goods and 

services; the Federal Management Regulation (FMR), which, among 

 

3

GAO-08-1044. 

4

Executive Order 13423, “Strengthening Federal Environmental, Energy, and 

Transportation Management.” 72 Fed. Reg. 3,919 (Jan. 26, 2007); and Executive Order 

13514. “Federal Leadership in Environmental Energy, and Economic Performance,” 74 

Fed Reg. 52,117 (Oct. 8, 2009).

5

GAO, Data Center Consolidation: Agencies Need to Complete Inventories and Plans to 

Achieve Expected Savings, GAO-11-565 (Washington, D.C.: July 19, 2011) and Green 

Information Technology: Agencies Have Taken Steps to Implement Requirements, but 

Additional Guidance on Measuring Performance Needed, GAO-11-638 (Washington D.C.: 

July 28, 2011).
 

Page 3 GAO-12-74 Electronic Waste

other things, regulates the disposal of federal personal property, including 

electronics;6

To address the second objective, we selected a nonprobability sample of 

five federal agencies—the Departments of Defense (DOD), Energy 

(DOE), Education (Education), and Housing and Urban Development 

(HUD); and the National Aeronautics and Space Administration (NASA)—

to examine how the federal policy framework is carried out in those 

agencies. We selected DOD, DOE, and NASA because they each 

participated to some extent in EPA’s Federal Electronics Challenge (FEC) 

program and purchased large amounts of electronic products—ranking 

first, eighth, and tenth, respectively, in terms of overall federal agency 

information technology spending in fiscal year 2010. We selected 

Education because, according to the FEC program manager, the agency 

actively participates in the FEC and centrally manages its electronics 

procurement and disposal functions. We selected HUD because the 

agency was not participating in the FEC. Because we based the selection 

of agencies on a nonprobability sample, the information we obtained is 

not generalizable to all federal agencies. However, since the 

nonprobability sample consists of a cross-section of agencies of different 

sizes and levels of participation in the FEC, the evaluation of these five 

agencies provides examples of different procurement and disposition 

methods for electronics. We also obtained data on GSA’s federal excess 

personal property utilization, donation, and sales programs for fiscal year 

2010 to determine, for agencies using these programs, the extent to 

which they utilized each disposition method for their used electronics. We 

also designed and implemented a data collection instrument to collect 

data from the five selected agencies on how they disposed of electronic 

products for fiscal years 2009 and 2010. We attempted to resolve 

inconsistencies in the data provided through these efforts, but we 

determined that the data were not sufficiently reliable for the purpose of 

reporting on amounts of electronics disposed of by the five agencies or 

the extent to which agencies reutilize, donate, and sell used electronics 

the General Services Administration’s (GSA) Personal 

Property Disposal Guide, which serves as an index and quick-reference 

guide to personal property management provisions in the FMR; and other 

relevant electronics stewardship guidance.

 

6

The Federal Management Regulation requires that executive agencies to the maximum 

extent practicable fill requirements for personal property by using existing agency property 

or by obtaining excess property from other federal agencies in lieu of new procurements. 

See FMR, Subchapter B-Personal Property, 41 C.F.R. Pt. 102-36, §102-36.65 (2011). 
 

Page 4 GAO-12-74 Electronic Waste

through GSA’s federal excess personal property programs. We discuss 

these data problems in our report. We also met with officials responsible 

for procuring and disposing of electronic products for the five federal 

agencies, and we conducted site visits to the Kennedy Space Center in 

Cape Canaveral, Florida, and Defense Logistics Agency (DLA) Aviation in 

Richmond, Virginia, to discuss the procurement and disposition of 

electronic products. We also visited three recycling facilities that have a 

role in electronics recycling at federal agencies and interviewed facility

officials about recycling procedures. We examined key provisions of the 

July 2011 National Strategy for Electronics Stewardship and compared 

them with existing policies for electronics stewardship. We also obtained 

information from the FEC program’s manager, officials within each of the 

five agencies, and seven champions for the FEC program regarding 

challenges that may affect agency participation in electronics stewardship 

initiatives. Details of our scope and methodology are in appendix I.

We conducted this performance audit from October 2010 to January 2012 

in accordance with generally accepted government auditing standards.

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

As we have reported previously, EPA estimates that across the federal 

government 10,000 computers are disposed of each week.7

 

7

GAO, Federal Electronics Management: Federal Agencies Could Improve Participation in 

EPA’s Initiatives for Environmentally Preferable Electronic Products, 

Once these 

used electronics reach the end of their original useful lives, federal 

agencies have several options for disposing of them. Agencies generally 

are to donate their used electronics to schools or other nonprofit 

educational institutions; exchange them with other federal, state, or local 

agencies; sometimes trade them with vendors to offset the costs of new 

equipment; sell them—generally through the GSA’s surplus property 

program, which sells surplus federal government equipment, including 

used federal electronics, at public auctions; or give them to a recycler.

GAO-10-196T

(Washington, D.C.: Oct. 27, 2009).

Background
 

Page 5 GAO-12-74 Electronic Waste

Federal agencies, however, are not required to track the ultimate 

destination of their donated or recycled used electronic products. Instead, 

agency officials generally consider this to be the recipient organization’s 

responsibility. Consequently, federal agencies often have little assurance 

that their used electronics are ultimately disposed of in an 

environmentally responsible manner. In our prior work, we found that little 

information exists, for example, on whether obsolete electronic products 

are reused, stored, or disposed of in landfills.8 If discarded domestically 

with common trash, a number of adverse environmental impacts may 

result, including the potential for harmful substances such as cadmium, 

lead, and mercury to enter the environment. If donated or recycled, these 

products may eventually be irresponsibly exported to countries without 

modern landfills and with waste management systems that are less 

protective of human health and the environment than those in the United 

States. For example, in our prior work we found that some U.S. 

electronics recyclers—including ones that publicly tout their exemplary 

environmental practices—were apparently willing to circumvent U.S. 

hazardous waste export laws and export certain regulated used electronic 

products to developing countries.9

The federal government’s approach to ensuring environmentally 

responsible management of used electronics has relied heavily on EPA’s 

FEC initiative, which, among other things, encourages federal facilities 

and agencies to manage used electronics in an environmentally safe way.

In addition, executive orders were issued to strengthen federal agencies’ 

overall environmental management practices, including environmentally 

sound management of federal electronic products. The Office of 

Management and Budget (OMB), the White House Council on 

Environmental Quality (CEQ), and the Office of the Federal 

Environmental Executive (OFEE) each play important roles in providing 

leadership, oversight, and guidance to assist federal agencies with 

implementing the requirements of these executive orders.10

 

8

GAO, Electronic Waste: Strengthening the Role of the Federal Government in 

Encouraging Recycling and Reuse, 

More 

GAO-06-47 (Washington, D.C.: Nov. 10, 2005). 

9

GAO-08-1044. 

10OFEE is responsible for promoting sustainability and environmental stewardship 

throughout federal government operations. It was created by executive order in 1993, is 

housed at the President’s Council on Environmental Quality, is administered by EPA, and 

leads the interagency Steering Committee on Federal Sustainability.
 

Page 6 GAO-12-74 Electronic Waste

recently, an interagency task force issued the July 2011 National Strategy 

for Electronics Stewardship,

11 which is intended to lay the groundwork for 

enhancing the federal government’s management of used electronics.

Over the past decade, the executive branch has undertaken several 

initiatives to improve federal agencies’ management of used electronics.

Specifically, (1) EPA has led or coordinated several improvement 

initiatives and issued guidance aimed at improving the management of 

used federal electronic products, (2) GSA has issued personal property 

disposal guidance and instituted new requirements for electronics 

recyclers it has contracted with to dispose of federal electronic products, 

(3) the President has issued executive orders that established goals for 

improving the management of used federal electronics, and (4) an 

interagency task force issued the July 2011 National Strategy for 

Electronics Stewardship, which is intended to lay the groundwork for 

enhancing the federal government’s management of used electronics.

EPA has led or coordinated several key improvement initiatives to assist

agencies with the management of used federal electronics, including the 

FEC, the Federal Electronics Stewardship Working Group, and the 

establishment of electronics recycler standards for use in certification 

programs.

Federal Electronics Challenge. In 2003, EPA, along with several other 

agencies, piloted the FEC.12

 

11White House Council on Environmental Quality, Environmental Protection Agency, 

General Services Administration, National Strategy For Electronics Stewardship

(Washington, D.C.: July 20, 2011),

The FEC is a voluntary partnership program 

that encourages federal facilities and agencies to purchase 

environmentally friendly electronic products, reduce the impacts of these 

products during their use, and manage used electronics in an 

environmentally safe way. To participate, executive branch agencies or 

http://www.gsa.gov/graphics/admin/National_Strategy_Electronics_Stewardship_2011.pdf

12A memorandum of understanding signed by the Executive Office of the President and 11 

agencies in November 2004 formally committed the agencies to join the FEC as agency 

partners and to actively sponsor participation of all facilities within each agency. The 11 

agencies were the Departments of Agriculture, Defense, Energy, Health and Human 

Services, Homeland Security, the Interior, Justice, Transportation, and Veterans Affairs; 

and the Environmental Protection Agency and General Services Administration.

Key Initiatives to 

Improve Federal 

Agencies’ 

Management of Used 

Electronic Products 

Have Been Launched 

over the Past 10 Years 

EPA Has Led Initiatives 

Aimed at Improving the 

Management of Used 

Federal Electronics
 

Page 7 GAO-12-74 Electronic Waste

their facilities must register and sign an agency pledge to become an 

agency or facility FEC partner, or both. In general, agency partners are 

responsible for supporting their facilities’ efforts but do not have specific 

reporting requirements. Facility partners are required to submit a baseline 

survey of their electronics stewardship activities when they join the 

program. The survey is to include, among other things, a description of 

(1) what the entity does with electronic products that are no longer used; 

(2) which electronics recycling services it uses; and (3) what, if any, 

measures the entity has taken to ensure that the electronic products were 

recycled in an environmentally sound manner.13

FEC guidance directs participants to provide recipients of donated 

electronics with instructions on how to have the electronics recycled 

responsibly and how to verify that responsible recycling occurs—

procedures known as “downstream auditing.” When donating used 

electronics, FEC instructs agencies and facilities to ensure that recipients 

contact local or state environmental or solid waste agencies to obtain a 

database of vendors who recycle used electronics once the equipment is 

no longer useful to the recipient organization. FEC also recommends that 

participating agencies and facilities instruct recipients to avoid 

arrangements with recyclers that are unable or unwilling to share 

references and cannot explain the final destination of the used electronics 

they collect. When recycling electronics, participants are to determine 

how much electronic equipment the recyclers actually recycle compared 

with the amount they sell to other parties. In addition, FEC instructs 

participants to physically inspect a potential recycler’s facilities. Used 

electronics in trash containers, for example, may indicate that the facility 

is not recycling it, and the presence of shipping containers may indicate 

that the facility exports it.

Facility partners are also 

expected to report progress annually, and apply for recognition through 

FEC awards.

To assist FEC partners, “FEC champions” are available to help regional 

federal facilities with their electronics management programs. FEC 

 

13The FEC Baseline Survey and Annual Reporting Form was developed to measure 

partners’ progress against the FEC national program goals. The information collected may 

be translated into the partner’s and program’s environmental benefits using the 

Electronics Environmental Benefits Calculator, an EPA-developed online tool that 

estimates the environmental benefits of improving the purchasing, use, and disposal of 

computer products and electronic equipment.
 

Page 8 GAO-12-74 Electronic Waste

champions are EPA representatives who are selected based on 

geographic representation. Champions help federal facilities become FEC 

facility partners; access resources for managing electronic products, 

including FEC program information, fact sheets, and limited technical 

assistance; and receive recognition for improving electronics 

management programs.

The Federal Electronics Stewardship Working Group. This working group 

coordinates interagency efforts to promote federal electronics 

stewardship. It also acts as an advisory board for the FEC program.

During the working group’s monthly meetings, federal agencies have the 

opportunity to discuss best practices for implementing the FEC and other 

electronics stewardship initiatives within their respective agencies. The 

FEC Program Manager told us the working group meetings serve as a 

primary mechanism to facilitate communication with agency management 

regarding the FEC program. Most executive agencies have at least one 

representative serving with the working group. 

Standards for certification of recyclers. EPA has worked with the recycling 

industry and other entities to promote partnership programs that address 

the environmentally sound management of used electronic products. As 

we reported in July 2010, EPA convened electronics manufacturers, 

recyclers, and other stakeholders and provided funding to develop 

Responsible Recycling (R2) practices, so that electronics recyclers could 

obtain certification to show that they are voluntarily adhering to the 

adopted set of best practices for environmental protection, worker health 

and safety, and security practices.14

 

14GAO, Electronic Waste: Considerations for Promoting Environmentally Sound Reuse 

and Recycling, 

Certification for R2 practices became 

available in late 2009. The R2 practices identify “focus materials” in used 

electronic products, such as cathode-ray tubes or items containing 

mercury, that warrant greater care owing to their toxicity and associated 

risk if managed without the appropriate safeguards. Specifically, the 

practices require that recyclers and each vendor in the recycling chain (1) 

export products and components containing certain materials only to 

countries that can legally accept them, (2) document the legality of such 

exports, and (3) ensure that the material is being safely handled 

throughout the recycling chain. R2 practices also establish a “reuse, 

recover, dispose” hierarchy along the chain of custody for material 

GAO-10-626 (Washington, D.C.: July 12, 2010).
 

Page 9 GAO-12-74 Electronic Waste

handling. These practices require recyclers to test electronics diverted for 

reuse, and confirm that key functions of the unit are working before it may 

be exported. Without such testing and confirmation, these used 

electronics must be treated as though they are going to recycling and 

may not be exported unless the R2 exporting provisions for recycling are 

satisfied. Recognizing that some clients would not want their used 

electronics remarketed or reused, R2 practices also require recyclers to 

have systems in place to ensure that all such electronics processed can

be recycled, rather than recovered for reuse.

EPA encourages electronics recyclers to obtain certification to either R2 

practices, or to e-Stewards, a separate voluntary certification program. eStewards was initiated by the Basel Action Network in 2008, and the first 

e-Stewards-certified facilities were announced in early 2010.15 The length 

and cost of the e-Stewards certification process depends on a facility’s 

size and whether it has a documented environmental management 

system in place.16

In March 2006, to assist agencies in understanding the requirements 

associated with personal property disposal, GSA published the Personal 

Property Disposal Guide.

17 Federal law requires that executive agencies, 

as much as possible, obtain needed goods, including electronic products, 

by using existing agency property or by obtaining excess property from 

other federal agencies in lieu of new purchases.18

 

15The Basel Action Network was founded in 1997 and named after the Basel Convention, 

the treaty under which parties have agreed to restrict trade in hazardous wastes and, 

among other things, prohibit export of toxic waste to developing nations deemed unable to 

manage the wastes in an environmentally sound manner.

According to the GSA 

guide, agencies should follow a hierarchy for disposing of excess 

personal property, including used electronic products: reutilization, 

donation, sale, and abandonment or destruction.

16EPA recognizes both the R2 and e-Stewards programs, but does not audit or certify 

facilities for compliance with either of these certification programs. 

17This guide is available online at 

http://www.gsa.gov/graphics/fas/5-06-00389_R2-yWC-w_0Z5RDZ-i34K-pR.pdf.

1840 U.S.C. § 524(b); FMR Subchapter B-Personal Property, 41 C.F.R. § 102-36.65 

(2011).

GSA Has Issued Personal 

Property Disposal 

Guidance and Instituted 

New Requirements for 

Electronics Recyclers 

Listed on GSA’s Contract 

Schedule
 

Page 10 GAO-12-74 Electronic Waste

• Reutilization. In general, all excess personal property,19

• Donation. If computers and other electronic products cannot be 

reused internally or by another federal entity, an agency can also 

donate these products directly to a school or other eligible nonprofit 

organization through the Computers for Learning program.

including 

used electronic products, should be reported to GSA—preferably 

through the GSAXcess website. Personal property registered on the 

site is then available to other federal agencies and eligible state and 

nonprofit recipients who are seeking such property.

20,21 If a 

school declines the offer, the products must be reported to GSA for 

possible donation through the Federal Surplus Personal Property 

Donation Program.22

• Sales. If an agency’s property is not transferred or donated, it can be 

sold through public auctions. For example, the GSA Auctions® 

website offers the general public the opportunity to bid electronically 

on a wide array of federal assets, including used federal electronic 

products. Registered participants may bid on a single item or multiple 

items (lots) within specified time frames. In addition, in some cases 

federal agencies can sell their used electronic products on other 

internet auction sites.

• Abandonment or destruction. An agency is allowed to abandon or 

destroy property, including used electronics, if an agency official 

determines that (1) the property has no commercial value, either as 

an item or as scrap; or (2) the cost of care, handling, and preparation 

 

19Excess personal property is property under the control of any federal agency that is no 

longer required for that agency’s needs, as determined by the agency head or designee.

20The authority for federal agencies to transfer research equipment, including computers, 

to educational institutions and nonprofit organizations was established in law in 1992. See 

15 U.S.C. § 3710(i) (2011).

21The Computers for Learning program facilitates the transfer of excess federal computer 

equipment to schools and educational nonprofit organizations. The program implements 

Executive Order 12999, Educational Technology: Ensuring Opportunity for All Children in 

the Next Century, 61 Fed. Reg. 17,227 (Apr. 19, 1996). 

22The Federal Surplus Personal Property Donation Program enables certain nonfederal 

organizations, such as public agencies, nonprofit educational and public health activities, 

public airports, and educational activities of special interest to the Armed Forces, to obtain 

personal property that the federal government no longer needs. 
 

Page 11 GAO-12-74 Electronic Waste

of the property for sale would be greater than the expected sales 

proceeds.23

More recently, GSA has instituted new requirements for electronics 

recyclers listed on the GSA Schedule.24 In February 2011, GSA began 

requiring proof of certification under either R2 or e-Stewards for new 

vendors seeking to provide recycling or disposal services for used 

electronic products under GSA’s environmental services schedule.25

According to GSA officials, they also identified 5 vendors, out of the 58 

vendors on the schedule at that time, that were performing recycling or 

disposal services for used electronic products and provided these 

vendors with modified contract terms—making R2 or e-Stewards 

certification within 6 months a condition for performing these services 

under the GSA schedule.

In January 2007, Executive Order 13423 established goals for federal 

agencies to improve the management of their used electronic products.

Among other things, the executive order required that agency heads (1) 

establish and implement policies to extend the useful life of agencies’ 

electronic equipment and (2) ensure the agency uses environmentally 

sound practices with respect to the disposition of the agency’s electronic 

equipment that has reached the end of its useful life. Furthermore, the 

instructions for implementing the executive order, issued on March 28, 

2007, called for each agency to develop and submit to OFEE by May 1, 

2007, an electronics stewardship plan to implement electronics 

stewardship practices for all eligible owned or leased electronic products.

Among other things, the plans were to address how agencies will ensure 

 

23According to the GSA guidance, agencies are not to abandon or destroy property in a 

manner that is detrimental or dangerous to public health or safety. Specific requirements 

for the utilization and disposal of hazardous material are found in 41 C.F.R. Pt. 101-42 

(2011). Hazardous material may include property that possesses special characteristics, 

which in the opinion of the holding agency could be hazardous to health, safety, or the 

environment if improperly handled, stored, transported, disposed of, or otherwise 

improperly used.

24Under the GSA Schedules program, GSA establishes long-term governmentwide 

contracts with commercial firms to provide access to millions of commercial supplies 

(products) and services at volume discount pricing.

25The purpose of GSA’s Environmental Services Schedule for Materials and Waste 

Recycling and Disposal Services (899-5) is to assist federal agencies in choosing 

recyclers that GSA has determined meet certain requirements for various services. 

Executive Orders Issued in 

2007 and 2009 Established 

Goals for Improving the 

Management of Used 

Federal Electronics
 

Page 12 GAO-12-74 Electronic Waste

that all electronic products no longer needed by an agency are reused, 

donated, sold, or recycled using environmentally sound management 

practices at end of life. The implementing instructions called for agencies’ 

plans to

• comply with GSA procedures for the transfer, donation, sale, and 

recycling of electronic products (discussed above), as well as any 

applicable federal, state, and local laws and regulations; and

• use national standards, best management practices, or a national 

certification program for electronics recyclers.

The implementing instructions for Executive Order 13423 also directed 

each agency and its facilities to participate in the FEC or to implement an 

equivalent electronics stewardship program that addresses the purchase, 

operation and maintenance, and end-of-life management strategies for 

electronic products consistent with the FEC’s recommended practices 

and guidelines.

In October 2009, Executive Order 13514 built on the previous executive 

order but included slightly different goals for electronics stewardship.

Executive Order 13514 calls for agencies to develop, implement, and 

annually update strategic sustainability performance plans to specify how 

they intend to achieve the goals of the order. Agencies were required to 

submit fiscal year 2010 plans to CEQ and OMB by June 2010. Executive 

Order 13514, however, did not supersede or revoke the earlier executive 

order, and that order’s goals and requirements remain in effect.26

 

26See Omnibus Appropriations Act, 2009, Pub. L. No. 111–8 § 748, 123 Stat. 693 

(providing that Executive Order 13423 shall remain in effect hereafter except as otherwise 

provided by law).
 

Page 13 GAO-12-74 Electronic Waste

In July 2011, an interagency task force,27

• through interagency collaboration and with public input, a 

comprehensive and governmentwide policy on used federal electronic 

products that maximizes reuse, clears data and information stored on 

used equipment, and ensures that all federal electronic products are 

processed by certified recyclers; and

co-chaired by CEQ, EPA, and 

GSA, issued the National Strategy for Electronics Stewardship, which 

describes goals, action items, and projects that are intended to lay the 

groundwork for enhancing the federal government’s management of used 

electronic products, among other things. The strategy assigns primary 

responsibility for overseeing or carrying out most of the projects to either 

EPA or GSA. Most of the projects are scheduled for completion from 

summer 2011 through spring 2013. Among other things, the strategy 

directs GSA to issue

• revised reporting guidance to improve federal agencies’ tracking of 

used federal electronic products throughout their life cycle and to post 

comprehensive data on Data.gov and other publicly accessible 

websites.28

The strategy also recommends that the federal government

• require and enable recipients of used federal equipment that has been 

sold, transferred, or donated for reuse to use certified recyclers and 

follow other environmentally sound practices to the greatest extent 

possible; and

• encourage electronics manufacturers to expand their product takeback programs, and use certified recyclers as a minimum standard in 

those programs by expanding the use of manufacturer take-back 

 

27The interagency task force is separate from the Federal Electronics Stewardship 

Working Group referenced earlier in the report.

28Data.gov was launched in 2009 and its purpose is to increase public access to highvalue, machine-readable datasets generated by the executive branch of the federal 

government. 

The National Strategy for

Electronics Stewardship

Aims to Improve the 

Federal Government’s 

Management of Used 

Electronics
 

Page 14 GAO-12-74 Electronic Waste

agreements in federal electronics purchase, rental, and service 

contracts.29

According to our review of agency documents and discussions with 

agency officials, federal agencies have made some progress to improve 

their management of used electronic products, as measured by greater 

participation in the FEC and an increase in certified electronics recyclers, 

but opportunities exist to expand their efforts. In addition, challenges 

remain that may impede agencies’ progress toward further improving their 

management of used federal electronics, including in the tracking and 

reporting of data on the disposition of used federal electronics, in 

clarifying agencies’ responsibility for used electronics sold through 

auctions, and in clarifying definitions for key terms and reconciling 

differences between the executive orders.

Since we first reported on the FEC in November 2005,30

 

29Some electronics manufacturers have created product take-back programs; in these 

programs, consumers return used equipment to the manufacturers, and the manufacturers 

manage the equipment’s reuse, recycling, or disposal. Take-back programs are common 

among large electronic products manufacturers, such as Apple, Dell, and HewlettPackard. 

participation has 

grown from 12 agencies and 61 individual facilities to 19 agencies and 

253 individual facilities, as of September 2011. However, participation still 

represents only about one-third of the federal workforce and, in some 

cases, participation means that an agency has identified its current 

practices for managing electronic products and set goals to improve them 

but has not reported on progress toward achieving these goals as 

required. Specifically, only a little more than half of the agencies and 

facilities that were registered as FEC partners submitted an annual 

accomplishment report in 2010 to demonstrate the agency or facility’s 

progress in electronics stewardship; these reports are a key component 

of actively participating as a partner. Because FEC participation is 

voluntary, EPA officials said EPA has no authority to require agencies to 

report on their progress. As a result, the extent to which agencies that do 

not report progress are reaching their goals is unknown. However, the 

FEC program manager told us that with a recent change in policy, FEC 

30GAO-06-47.

The Management of 

Used Federal 

Electronics Has 

Improved and 

Opportunities Exist 

for Further 

Improvements, but 

Challenges Remain

FEC Participation Has 

Grown, and Opportunities 

Exist to Increase 

Participation
 

Page 15 GAO-12-74 Electronic Waste

facility partners that do not submit their fiscal year 2011 annual reporting 

form by January 31, 2012, will be considered inactive. An FEC official 

stated that despite increased efforts to market the program, some 

agencies find the FEC’s reporting requirements to be time-consuming.

For the five agencies we reviewed, participation in FEC varied.

Specifically:

• DOD participates in the FEC as an agency partner, but the majority of 

its installations or facilities do not participate. According to EPA data, 

16 of DOD’s approximately 5,000 installations participate in the FEC. 

DOD officials told us that they are conducting outreach to encourage 

installations to participate but that some installations may not 

participate because officials believe that the registration process is too 

rigorous and burdensome.

• NASA centers are allowed to participate in the FEC, but they are not 

required to do so because other agency initiatives accomplish the 

same goals, according to agency officials. Three of NASA’s 10 

centers participate in the FEC.

• HUD does not participate in the FEC. We found that agency officials 

did not understand the FEC participation requirements. HUD’s 

electronics stewardship plan states that HUD participates in the FEC, 

but an EPA official, who is responsible for the FEC program, told us 

that HUD never registered to become a partner—which involves 

submitting a baseline survey of the agency’s electronics stewardship 

activities. In our discussions with HUD officials, we found that they 

were not aware of the FEC registration or reporting requirements and 

continued to believe that the agency was participating.

• DOE officials promote FEC participation, submit annual 

accomplishment reports, and actively participate in the FEC awards 

program. According to agency officials, over a 6-year period, 23 DOE 

facilities have won FEC awards, with many winning multiple times. All 

but two DOE facilities participate.

• Education participates in the FEC as an agency and facility partner.

However, because it centrally manages the purchasing and 

disposition of electronics, Education submits annual accomplishment 

reports for the agency as a whole.
 

Page 16 GAO-12-74 Electronic Waste

For those agencies or facilities that actively participate in the FEC, 

participation can provide federal officials with the information and 

resources31 needed to provide greater assurance that their used 

electronics are disposed of in an environmentally responsible manner, 

according to EPA documents. For the five agencies we reviewed, officials 

at agencies or facilities that actively participated in the FEC said that the 

FEC provided invaluable support. For example, according to DOD 

officials at one installation, the information sharing that is facilitated 

through the FEC is one of the biggest benefits of participation—when 

faced with a problem, the FEC can provide information from other 

agencies that have faced comparable problems. Similarly, Education 

officials told us that membership in Federal Electronics Stewardship 

Working Group was very helpful. In addition, DOE officials said that they 

have had much success with the FEC program and that the FEC awards 

program has motivated many DOE facilities to participate in electronics 

recycling.

Since the R2 and e-Stewards certification processes were made available 

in 2009 and 2010, respectively, the number of certified recyclers in the 

United States has grown greatly. From September 2010 to September 

2011, the number of electronics recycling facilities certified to the R2 

standard increased from 15 to 122 and the number of facilities certified to 

the e-Stewards standard grew from 6 to 40. Figure 1 shows the locations 

of the electronics recycling facilities in the United States that have 

obtained third-party certification as of September 30, 2011.

 

31Resources include instruction sheets, tips, and checklists, among other things, which 

participants can choose to use. 

The Number of Certified 

Recyclers Has Grown and 

Opportunities Exist for 

Agencies to Increase 

Their Use
 

Page 17 GAO-12-74 Electronic Waste

Figure 1: Electronics Recycling Facilities Certified to the R2 or e-Stewards Standard, as of September 30, 2011

The increased number of certified recyclers should make it easier for 

agencies to locate recyclers that will, among other things, ensure that any 

harmful materials are being safely handled throughout the recycling 

chain. For the five agencies we reviewed, almost no certified recyclers 

were used, and in most cases agency officials either misidentified a 

recycler’s certification status or indicated that they did not know the 

recycler’s certification status. According to our analysis of the disposition 

information these agencies provided, of the 25 electronics recycling 

companies that the five agencies reported using in fiscal year 2010, only 

one was certified by either R2 or e-Stewards for all locations where the 

agency used it as of September 30, 2010, and agencies were correct in 
 

Page 18 GAO-12-74 Electronic Waste

identifying whether or not their recyclers were certified in only four 

cases.32

The confusion regarding electronics recyclers’ certification status could 

stem in part from the absence of clear guidance. The implementing 

instructions for Executive Order 13423 direct agencies to use national 

standards, best management practices, or a national certification program 

for recyclers. To date, however, none of the oversight agencies—OMB, 

CEQ, and OFEE—have provided agencies with clear guidance specifying 

whether R2 or e-Stewards, the two existing certification programs, qualify 

as “national certification programs for recyclers” under the implementing 

instructions.33

In an effort to address this issue, according to the National Strategy for 

Electronics Stewardship, EPA and GSA are to take steps to address the 

need for well-defined requirements for those certification programs that 

federal agencies will rely upon. Specifically, EPA, in consultation with 

GSA and other relevant agencies, is to develop a baseline set of 

electronics recycling criteria to ensure, among other things, that all 

downstream handlers of used electronics manage these materials in a 

way that protects the environment, public health, and worker safety. EPA 

is also to initiate a study of the current electronics certification programs 

to evaluate the strength of their audits of downstream facilities. According 

to the national strategy, as part of its effort to establish a comprehensive 

and governmentwide policy on used federal electronic products, GSA will 

consider the baseline set of criteria, the results of the study of current 

certification programs, and other requirements and considerations in 

determining which certification programs satisfy the governmentwide 

requirement to use certified recyclers. Although the strategy calls for GSA 

to, with public input, issue a revised policy and propose changes to the 

FMR, it is unclear if GSA is on track to do this by February 2012, given 

that it has not issued a public draft, nor conducted a public comment or 

other public input process. Similarly it is unclear when, if, or how GSA’s 

revised policy component regarding certified recyclers will be 

incorporated into the FMR. Moreover, it is unclear what mechanism GSA 

 

32Of the 25 electronics recyclers used by the five agencies in fiscal year 2010, four had 

obtained either R2 or e-Stewards certification as of September 30, 2011 for all locations 

used by the agencies.

33EPA has formally recognized these programs on its website. 
 

Page 19 GAO-12-74 Electronic Waste

will use to issue the revised policy prior to its inclusion in the FMR, as the 

policy may not be in conformance with the current FMR. In addition, the 

national strategy does not specify if or how EPA and GSA will routinely 

update other federal agencies on the status of their efforts to implement 

the national strategy’s recommendations.34

Currently, due to challenges associated with the tracking and reporting of 

used federal electronics, the ultimate disposition of these electronics is 

unknown—making it difficult to measure the effectiveness of Executive 

Orders 13423 and 13514, which were aimed at improving the 

management of used federal electronics and ensuring the proper disposal 

of electronics that have reached the end of their useful life. The National 

Strategy for Electronics Stewardship acknowledges the challenges 

associated with tracking and reporting the disposition of used federal 

electronics and proposes some solutions for improving the data that 

agencies report to GSA. Under the national strategy, GSA is to streamline 

and standardize reporting through the annual Report of Non-Federal 

Recipients35

If GSA intends to use this report to capture agencies’ data, it is unclear 

how the report will improve the quality of the limited data GSA currently 

receives. GSA officials told us that while the agency currently collects 

disposition data from agencies through its GSAXcess database, 

GSAXcess is not an accountable property system;

to gather data on the type, quantity, and intended use of 

electronic products leaving federal ownership, and the recipients of these 

products. It is unclear, however, what electronics the new reporting 

requirements will cover. The national strategy suggests that the annual 

Report of Non-Federal Recipients will be expanded to include the 

reporting of the disposition of electronic products to all recipients.

Currently, the report includes only property donated to such nonfederal 

recipients as schools and state and local governments, and therefore 

does not include the disposition of significant quantities of electronics.

36

 

34The benchmark document issued along with the national strategy states “As the National 

Strategy is implemented, the project benchmarks will be updated.”

therefore, data 

35Under 40 U.S.C. § 529, executive agencies must submit to GSA, following the close of 

each fiscal year, an annual report of personal property furnished to any nonfederal 

recipient during the previous fiscal year, known as the Report of Non-Federal Recipients.

36Accountable property systems are “systems of record” or systems that contain an 

agency’s official property records, according to GSA officials.

The Tracking and 

Reporting of Data on the 

Disposition of Used 

Electronics Presents 

Challenges
 

Page 20 GAO-12-74 Electronic Waste

validation is limited.37

The data challenges are further complicated by the fact that individual 

agency procedures for tracking electronics are not consistent. Agencies 

typically record the acquisition of electronics as individual units, such as 

desktop or laptop computers, and continue to track these electronics as 

individual units while in use at the agency. However, when agencies 

dispose of these same electronics, they may use a different method for 

tracking them. For example, rather than tracking the disposition of used 

electronic products as individual units, agencies may aggregate a number 

of similar items into a single line item or they may report them by weight.

In addition, a single agency may use different metrics for different types of 

disposition. For example, DLA, a DOD acquisition and disposition agency, 

tracks electronic products sent to recyclers in pounds and electronic 

products disposed of through other means—such as donated to schools 

or transferred to other agencies—by individual unit. Because some 

electronics are tracked and reported as line items and some are recorded 

in pounds, it is not possible to compare the extent to which the agency 

relies on one disposition method over another. For the five agencies we 

reviewed, data provided to us on the disposition of electronic products 

were similarly inconsistent, which hampered our efforts to accurately 

assess the extent to which electronic products procured by these federal 

agencies were disposed of in an environmentally sound manner.

According to a GSA bulletin, a number of executive 

agencies have not submitted reports to GSA on exchange/sale 

transactions and property furnished to nonfederal recipients, as currently 

required, or have not included all of the required information—thus 

presenting data challenges as GSA seeks to carry out its oversight and 

management responsibilities.

GSA’s personal property disposition procedures do not clarify agency 

responsibilities for tracking or placing contract conditions on the ultimate 

disposition of used electronics if they are sold through auctions. As we 

reported in August 2008, some electronics recyclers in the United 

States—including those that have purchased government electronics sold 

 

37GSA has built edit checks into the system requiring agencies to confirm amounts that 

are over certain dollar amounts.

Challenges Remain in 

Clarifying Agencies’ 

Responsibility for Used 

Electronics Sold through 

Auctions
 

Page 21 GAO-12-74 Electronic Waste

through auction—appeared willing to export regulated electronics 

illegally.38

We identified two auction disposal methods—those used by GSA and by 

DOD—that could result in used federal electronics being handled in an 

environmentally risky manner. Specifically, under the GSA auction process, 

registered participants can bid electronically on items within specific time 

frames. To participate, potential buyers register with GSA by providing 

information about themselves, such as name, address, and payment 

information, before they can bid on items, according to GSA officials. 

However, GSA officials told us that they do not evaluate the information 

obtained from buyers to determine whether they are brokers or resellers 

who might potentially export these used products to other countries where 

they may not be handled in an environmentally sound or safe manner. 

Moreover, GSA officials stated that the agency does not have enforcement 

authority after these items are sold to the general public. They told us that if 

GSA is made aware of any inappropriate activity or violations of the terms 

of the sale, it will refer the information to the GSA Inspector General for 

further investigation. According to agency documentation, GSA’s online 

auction procedures include standard sales terms and conditions, special 

security notifications, and export control clauses. However, none of the 

terms, conditions, or clauses included in GSA’s auction procedures are 

aimed at ensuring that (1) electronics containing certain materials39 are 

exported only to countries that can legally accept them,40

 

38

(2) recyclers 

document the legality of such exports, and (3) the material is being safely 

handled throughout the recycling chain.

GAO-08-1044. EPA has issued regulations specifically addressing management of 

cathode ray tubes, and imposing requirements on their handling and export.

39For example, the R2 practices identify “focus materials,” which include items such as 

cathode-ray tubes or items containing mercury that warrant greater care owing to their 

toxicity and associated risk if managed without the appropriate safeguards.

40GSA’s general sales terms and conditions contain general conditions requiring, among 

other things, that bidders comply with all applicable federal, state, local, and multijurisdictional laws, ordinances, and regulations, in the transportation, transfer, export, use, 

or disposal of the property, and that purchasers represent, warrant, and certify that they 

will use and ultimately dispose of any hazardous property purchased under 

GSAAuctions.gov site as stipulated under applicable federal, state, local, and international 

laws and regulations. As previously noted, however, most electronics are not considered 

“hazardous” under U.S. law.
 

Page 22 GAO-12-74 Electronic Waste

Unlike GSA, DOD is not directly involved in the auction process but 

instead sells its used electronics to a private company, which then resells 

the used electronics through its web-based auction process. According to 

DOD officials, DOD’s responsibility for tracking its used electronics ends 

once it passes to the contractor—Government Liquidation. DOD officials 

said that Government Liquidation has its own terms and conditions that 

bidders must adhere to once they purchase the used electronics. As with 

GSA auctions, the terms and conditions included in the Government 

Liquidation auctions are not aimed at ensuring that used federal 

electronics are exported only to countries that that can legally accept 

them.41 In our review of these auction websites, we found that the 

overwhelming majority of used electronic products are sold in bulk, which 

would indicate that they are being sold to brokers or resellers, not 

individual consumers.42

The National Strategy for Electronics Stewardship seeks to address the 

problems associated with used federal electronics sold through auction. 

According to the strategy, the electronics stewardship policy that GSA is to 

establish will prohibit the sale of nonfunctional electronics through public 

auction except to third-party certified recyclers and refurbishers. Functional 

electronics are to be directed through the existing hierarchy of transfer, 

donation, and sale. It is unclear, however, how this policy will work in 

practice. Currently, agencies sell electronics in mixed lots of potentially 

functional and nonfunctional equipment. For example, officials at one 

agency said that it was not cost effective to test items to ensure that they 

 

41Government Liquidation’s terms and conditions contain the general requirement that the 

buyer agrees to comply with all applicable export laws and regulations. However, most 

electronics are not considered “hazardous” under U.S. law, thus are not subject to EPA’s 

export rules for hazardous wastes. The terms also note that “[a]ny device which is 

damaged in transit or is found to be cracked, shattered or broken may subject the Buyer to 

regulations pertaining to the handling, storage, transportation, re-sale or disposal of 

electronic waste,” and generally cautions—but does not require—buyers “to use and 

ultimately dispose of any hazardous components or constituents according to all 

applicable local, national or international laws and regulations in a manner safe for the 

public and the environment.”

42Moreover, information on the potential for reuse of such equipment is unclear. These 

auctions are typically labeled as “scrap,” defined by Government Liquidation as “property 

sold for its material content value, and for which it is not intended that the property or any 

of its parts or components be used for its originally intended purpose.” Government 

Liquidation’s terms and conditions, however, state that it sells only useable electronic 

devices, including reparable devices, but that the company makes no warranties or 

representations regarding the electronic devices it sells.
 

Page 23 GAO-12-74 Electronic Waste

are functional; therefore, items are sold through GSA “as is” with no implied 

warranty. These agency officials said that they combine items in sales lots 

that will bring the most return to the federal government. In addition, we 

found that electronics listed on the Government Liquidation and GSA 

auction websites are frequently marketed as “tested to power-up only,” or 

with disclaimers such as “condition of the property is not warranted.” Under 

the national strategy, it is unclear whether electronics characterized in this 

way would qualify as “functional.” In addition, the national strategy does not 

provide clear and detailed criteria to assist federal agencies in bundling 

functional and nonfunctional electronics for sale exclusively to certified 

recyclers or refurbishers, distinguishing between functional and 

nonfunctional electronics by conducting specific tests, and labeling 

electronic products. Moreover, if federal agencies sell used functional 

electronic products through auctions, neither the agency nor the auction 

entities are required to impose conditions or to perform due diligence by 

conducting auditing to determine whether all downstream reusers of such 

products follow environmentally sound end-of-life practices.

In contrast, the European Union has detailed guidance for determining 

the functionality of electrical and electronic equipment, as part of 

distinguishing whether the equipment is considered waste in the context 

of import-export rules. The guidance states that the tests required to 

determine functionality depend on the type of electronics, but generally, 

completion of a visual inspection without testing functionality is unlikely to 

be sufficient for most types of electronics; it also states that a functionality 

test of the key functions is sufficient. The guidance also identifies defects 

that materially affect functionality and would therefore cause an item to be 

considered “waste” if, for example, the equipment did not turn on, perform 

internal set-up routines, or conduct self-checks.43 As discussed 

previously, R2 practices establish a similar “reuse, recover, dispose” 

hierarchy along the chain of custody for material handling and require 

recyclers to test electronics diverted for reuse, and confirm that key 

functions of the unit are working before it may be exported.44

 

43Regulation (EC) No 1013/2006 Revised Correspondents’ Guidelines No. 1, Shipments of 

Waste Electrical and Electronic Equipment (WEEE) (June 2007).

44Similarly, WRAP, a government-backed private nonprofit organization in the United 

Kingdom, recently issued a protocol establishing minimum recommended tests that 

computers and related equipment must pass to be considered functional and fit for reuse. 
 

Page 24 GAO-12-74 Electronic Waste

We found that key terms concerning electronics have not been defined 

and that differences between the executive orders have not been 

clarified. In particular:

• Key terms not defined. Key terms such as “electronic product” and 

“environmentally sound practices” are not explicitly defined in the 

executive orders, the guidance provided to agencies for implementing 

the executive orders, or the National Strategy for Electronics 

Stewardship. Consequently, each of the agencies we reviewed used 

its own definition of electronic products to report progress in 

implementing policies for electronics stewardship. For example, DOE 

defines electronic products as printers, desktop computers, notebook 

computers, and monitors; DOD, Education, HUD, and NASA use 

broader definitions that include servers, routers, and switches; cell 

phones and musical instruments; and refrigerators. Moreover, without 

a clear definition of what constitutes an environmentally sound 

practice, agencies are free to dispose of their used electronics 

through online auctions or other means that provide little assurance 

that (1) these electronics are exported only to countries that can 

legally accept them,45

• Differences between the executive orders have not been clarified. 

CEQ has not issued implementing instructions regarding electronics 

stewardship for Executive Order 13514, which was signed in 2009, 

and CEQ, OMB, and OFEE have not harmonized the electronics 

stewardship requirements contained in executive orders 13423 and 

13514. For example, under Executive Order 13423, the requirement 

to use environmentally sound practices applies to electronic 

equipment that has “reached the end of its useful life,” whereas 

Executive Order 13514 includes “all agency excess or surplus 

electronic products,” and the difference between these terms has not 

been clarified. In addition, the implementing instructions for Executive 

(2) recyclers document the legality of such 

exports, and (3) the material is being safely handled throughout the 

recycling chain.

 

45Under EPA regulations, used cathode-ray tubes are the only electronic device 

specifically regulated as hazardous waste and whose export is subject to controls. 

According to EPA statements, used electronic devices other than cathode-ray tubes do 

not generally qualify as hazardous waste under the Resource Conservation and Recovery 

Act of 1976 as amended, which is the statute governing hazardous waste handling and 

disposal. However, foreign countries may restrict the import of a wider range of used 

electronics. 

Challenges Remain in 

Defining Key Terms and in 

Clarifying Differences 

between the Executive 

Orders
 

Page 25 GAO-12-74 Electronic Waste

Order 13423 direct agencies to ensure that contracts for leased 

electronic equipment incorporate language that requires that at the 

end of the lease period, the equipment is reused, donated, sold, or 

recycled using environmentally sound management practices. This 

directive is not included in Executive Order 13514 nor in the guidance 

provided to agencies for preparing their strategic sustainability 

performance plan that is to be used under Executive Order 13514.

Officials from these oversight agencies told us that they have 

informed federal agencies that electronics stewardship plans under 

Executive Order 13423 can be incorporated by reference into their 

strategic sustainability performance plans to satisfy certain 

requirements for Executive Order 13514. Or alternatively, strategic 

sustainability performance plans may be used in lieu of separate 

electronics stewardship plans. However, CEQ, OMB, and OFEE have 

not addressed differences or updated the implementing instructions 

for Executive Order 13423.

Federal initiatives to improve the management of agencies’ used 

electronics—including the FEC, certification for recyclers, personal 

property disposal guidance, the executive orders, and the National 

Strategy for Electronics Stewardship—have sought to assist federal 

agencies in the handling of used electronic products. And progress has 

been made. More agencies and facilities are participating in the FEC, and 

a growing number of recyclers have received third-party certification.

However, opportunities exist to increase the breadth and depth of 

agencies’ participation in the FEC and to expand the use of certified 

electronics recyclers.

Federal agencies also face challenges that may impede their progress 

toward improving their management of used federal electronics.

Specifically, 2 years have elapsed since Executive Order 13514 required 

CEQ to issue implementing instructions. In the absence of such 

instructions, agencies do not have definitions for key terms such as 

“electronic products” and “environmentally sound practices,” and the 

guidance for implementing the executive orders provides inconsistent 

information on what procedures an agency should follow when 

implementing environmentally sound practices. In addition, 

inconsistencies between Executive Orders 13514 and 13423 have yet to

be addressed; without doing so, CEQ lacks assurance that agencies are 

meeting electronics stewardship requirements of both orders, given that 

CEQ and OMB permit agencies to comply using either an electronics 

stewardship plan under Executive Order 13423 or a strategic 

Conclusions
 

Page 26 GAO-12-74 Electronic Waste

sustainability performance plan under Executive Order 13514.

Furthermore, without consistent tracking and reporting of the disposition 

of used federal electronics, there is no mechanism to measure the 

effectiveness of federal policies aimed at ensuring the proper disposal of 

electronics that have reached the end of their useful life.

The recently issued National Strategy for Electronics Stewardship seeks 

to advance federal agencies’ efforts to manage used electronics.

However, it is unclear whether it will fully address challenges that impede 

environmentally sound management of used federal electronics.

Furthermore, it is doubtful whether the strategy will be effective without a 

mechanism for routinely keeping agencies and the public apprised of its 

progress toward establishing a governmentwide policy on used federal 

electronics—particularly with respect to use of third-party national 

certification for electronics recyclers—so that agencies have a clear 

understanding of their responsibilities and other interested parties are 

apprised of agencies’ progress toward completing actions identified in the 

strategy. Currently, the strategy does not state how agencies will be kept 

informed of implementation efforts. In addition, the strategy lays out an 

approach for ensuring that federal agencies dispose of nonfunctional 

electronics in a sound manner, but it does not provide clear and detailed 

criteria to assist federal agencies in bundling functional and nonfunctional 

equipment for sale exclusively to certified recyclers and refurbishers and 

distinguishing between functional and nonfunctional electronics by 

conducting specific tests and labeling electronic products. Finally, if 

federal agencies sell used functional electronic products through 

auctions, neither the agency nor the auction entities are required to 

perform due diligence by conducting auditing to determine whether all 

downstream reusers of such products follow environmentally sound endof-life practices.

To improve federal electronics stewardship, we are making the following 

four recommendations.

To support federal agencies’ efforts to improve electronics stewardship, 

we recommend that the Director of the White House Council on 

Environmental Quality, in collaboration with the Director of the Office of 

Management and Budget, and the Administrator of the General Services 

Administration collaborate on developing and issuing implementing 

instructions for Executive Order 13514 that

Recommendations for 

Executive Action
 

Page 27 GAO-12-74 Electronic Waste

• define key terms such as “electronic products” and “environmentally 

sound practices;” address inconsistencies between this executive 

order and Executive Order 13423; and as appropriate, provide clear 

direction on required agency actions under the national strategy; and

• require consistent information tracking and reporting on the 

disposition of used electronics among agencies.

To provide transparency on progress toward completing the actions 

identified in the National Strategy for Electronics Stewardship, we 

recommend that the Director of the White House Council on 

Environmental Quality, the Administrator of EPA, and the Administrator of 

GSA provide quarterly status updates on a publicly accessible website.

To ensure that electronic products procured by federal agencies are 

appropriately managed, we recommend that GSA include measures in its 

policy to ensure that all electronics sold through auction are appropriately 

managed once they reach the end of their useful lives. Such measures 

could include

• bundling functional and nonfunctional equipment for sale exclusively 

to certified recyclers, who would be responsible for determining the 

best use of the equipment under the “reuse, recover, dispose” 

hierarchy of management; or

• if agencies or GSA are to be responsible for screening electronics for 

auction and distinguishing between functional and nonfunctional 

equipment,

• providing clear and detailed criteria for doing so, such as specific 

testing and labeling; and

• ensuring that purchasers or recipients of functional electronic 

products sold through government auctions use certified recyclers 

or perform due diligence and conduct downstream auditing.

We provided a draft of this report to OMB, CEQ, GSA, and EPA for 

review and comment. In addition, we provided DOD, DOE, Education, 

HUD, and NASA with excerpts of the draft report that pertained to each 

agency and incorporated technical comments received as appropriate. In 

written comments, which are reproduced in appendix II, EPA generally 

concurred with our recommendations. OMB, CEQ, and GSA did not 

Agency Comments 

and Our Evaluation
 

Page 28 GAO-12-74 Electronic Waste

provide written comments to include in our report. Instead, in e-mails 

received on February 1, January 19, and January 17, 2012, from the 

agencies’ respective liaisons, OMB, CEQ, and GSA generally concurred 

with our recommendations. Even with their general concurrences, in 

some instances, the agencies proposed alternative approaches for 

executing the recommendations. In the e-mail from its liaison, OMB 

concurred with the comments in the e-mail from CEQ’s liaison but did not 

provide additional comments of its own.

In response to our recommendation that CEQ, in collaboration with OMB 

and GSA, issue implementing instructions for Executive Order 13514 that 

define key terms; require consistent information tracking and reporting; 

and provide clear direction on required agency actions under the national 

strategy, CEQ stated that it would reserve its decision regarding our 

recommendation until after GSA issues its comprehensive 

governmentwide policy on electronic stewardship. Specifically, CEQ 

stated that GSA’s policy would address the issues we identified with 

regard to unclear definitions and inconsistent tracking and reporting of 

electronics but was silent on how it would provide clear direction on 

required agency actions under the national strategy. GAO believes it is 

imperative for CEQ to issue implementing instructions along with GSA’s 

issuance of its policy. Without such instructions, agencies will lack clarity 

on required agency actions under the national strategy and whether 

adhering to the GSA policy is necessary and/or sufficient for 

implementing the executive order. Moreover, it remains unclear what 

mechanism GSA will use to issue its revised policy prior to its inclusion in 

the FMR, to the extent the current FMR does not conform with the new 

policy. Concerning this issue, GSA stated that it will publish guidance 

documents concurrent with proposing changes to the FMR. However, as 

GSA intends to issue guidance documents, which are not legally binding 

on agencies, as well as regulations, which are, it will be important for 

CEQ to issue implementing instructions that indicate which actions in the 

guidance documents, as well as any other actions beyond those in the 

FMR, are necessary to comply with the executive order.

In addition, as we recommended, CEQ, EPA, and GSA agreed that they 

would update a publicly accessible website on the status of progress 

toward completing the actions identified in the National Strategy for 

Electronics Stewardship. CEQ stated that progress reporting would be 

accomplished by GSA and GSA agreed to provide status updates at least 

quarterly. However, in its written comments, EPA requested that, instead 

of quarterly status updates, we revise our recommendation to require 

status updates as significant progress is made or key milestones are met. 
 

Page 29 GAO-12-74 Electronic Waste

EPA stated that due to the nature of some of the work the agencies have 

committed to as part of the national strategy, it may not be appropriate to 

report to the general public on a routine basis. We did not revise the 

recommendation and are not recommending such disclosure. Instead, we 

are recommending that the agencies provide a quarterly status update 

that characterizes the progress made toward achieving each action item 

or project. For example, one action item in the national strategy directed 

the Federal Electronics Stewardship Working Group to recommend to 

CEQ by November 18, 2011, metrics and other reporting tools to 

measure agencies’ progress in implementing the revised Federal 

Electronics Stewardship Policy. It would be helpful to have updated 

information on whether the working group has made its recommendation 

to CEQ and when CEQ will announce the new metrics and reporting 

tools. Currently, such information is not publicly available. In fact, as of 

February 8, 2012, more than 6 months after the policy and benchmarks 

were issued, no updates have been provided on publicly accessible 

websites.

With regard to our recommendation that GSA include measures in its 

electronic stewardship policy to ensure that all electronics sold through 

auction are appropriately managed once they reach the end of their 

useful lives, in the e-mail received from its liaison, GSA noted that the 

agency is working toward this goal. Specifically, GSA stated that it is 

working toward including measures to (1) bundle all equipment for sale to 

certified recyclers, who then determine proper reuse or recycling, or (2) 

provide agencies with clear, detailed criteria to distinguish between 

functional and nonfunctional electronics and ensure that purchasers or 

recipients of federal electronics use certified recyclers or perform 

downstream auditing, while also noting that GSA has limited authority to 

require recipients of used federal electronics to recycle them once 

ownership has transferred to those recipients. 
 

Page 30 GAO-12-74 Electronic Waste

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution for 30 days from the 

report date. At that time, we will send copies to the Secretaries of 

Defense, Education, Energy, and Housing and Urban Development; the 

Administrators of EPA, GSA, and NASA; the Director of OMB; the Chair 

of the White House CEQ; the Federal Environmental Executive; 

appropriate congressional committees; and other interested parties. The 

report also will be available at no charge on the GAO website at 

http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-3841 or ruscof@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of the report. GAO staff who made major contributions to 

this report are listed in appendix III.

Sincerely yours,

Frank Rusco

Director, Natural Resources 

and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-12-74 Electronic Waste

The objectives for this report were to examine (1) key initiatives aimed 

at improving the management of used federal electronics and 

(2) improvements resulting from these initiatives and challenges that 

impede progress toward improving the management of used federal 

electronics, if any.

To identify initiatives aimed at improving the management of used federal 

electronics, we reviewed guidance and other documents describing the 

Environmental Protection Agency (EPA) initiatives related to the Federal 

Electronics Challenge (FEC), the Federal Electronics Stewardship 

Working Group, and Responsible Recycling (R2) practices. We analyzed 

the requirements for electronic products contained in the applicable 

executive orders and implementing instructions that make up the federal 

policy framework; the Federal Acquisition Regulation, which governs the 

process through which the federal government acquires goods and 

services; the Federal Management Regulation (FMR), which, among 

other things, regulates the disposal of federal personal property, including 

electronics;1

To identify improvements resulting from federal initiatives to improve 

management of used federal electronics and challenges that impede 

progress, we selected a nonprobability sample of five federal agencies—

the departments of Defense (DOD), Energy (DOE), Education 

(Education), and Housing and Urban Development (HUD); and the 

National Aeronautics and Space Administration (NASA)—to examine how 

the federal policy framework is carried out in those agencies. We selected 

DOD, DOE, and NASA because they each participated to some extent in 

the FEC program and purchased large amounts of electronic products—

ranking first, eighth, and tenth, respectively, in terms of overall federal 

agency information technology spending in fiscal year 2010. We selected 

Education because, according to the FEC program manager, the agency 

actively participates in the FEC and centrally manages its electronics 

and the General Services Administration’s (GSA) Personal 

Property Disposal Guide, which serves as an index and quick-reference 

guide as it relates to personal property management provisions in the 

FMR; and other relevant electronics stewardship guidance. We also 

reviewed the July 2011 National Strategy for Electronics Stewardship. 

 

1

The FMR, Subchapter B-Personal Property. 41 C.F.R. Pt. 102-36, requires that executive 

agencies, to the maximum extent practicable, fill requirements for personal property by 

using existing agency property or by obtaining excess property from other federal 

agencies in lieu of new procurements. 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-12-74 Electronic Waste

procurement and disposal functions. We selected HUD because the 

agency was not participating in the FEC. We used FEC participation as a 

selection criterion because we hoped to include agencies with a range of 

experience with managing used electronics in an environmentally safe 

way. Because the selection of agencies was based on a nonprobability 

sample, the information we obtained is not generalizable to all federal 

agencies. However, because the nonprobability sample consists of a 

cross-section of agencies of different sizes and levels of participation in 

the FEC, the evaluation of these agencies provides relevant examples of 

different procurement and disposition methods for electronics. For these 

five agencies we also collected and reviewed fiscal year 2010 strategic 

sustainability performance plans. We also conducted semistructured 

interviews with officials from the Office of Management and Budget 

(OMB), the White House Council on Environmental Quality (CEQ), the 

Office of the Federal Environmental Executive (OFEE), and EPA to 

discuss their respective roles in assessing agency performance and 

managing the FEC and other federal initiatives for electronics 

stewardship. In some cases, we followed up the interviews with additional 

questions, and on two occasions, CEQ provided us with written 

responses to some of our questions on the roles of OMB, CEQ, and 

OFEE and other issues on federal electronics stewardship, such as how 

OMB and CEQ decide on whether an agency’s program is equivalent to 

the FEC. In addition, at GSA, we conducted semistructured interviews 

with officials on the agency’s policies and procedures for the transfer, 

donation, sale, and recycling of electronic products.

To determine the extent to which agencies used various disposition 

methods (i.e., reuse, donation, and sale) we analyzed governmentwide 

GSA data from GSAXCess, Exchange Sale, and Non-Federal Recipients 

reports for fiscal year 2010. We designed and implemented a data 

collection instrument to collect agency-specific disposition data for fiscal 

years 2009 and 2010 from the five agencies selected for our 

nonprobability sample. We encountered a number of limitations in 

obtaining reliable data. For example, GSA officials acknowledged that 

GSA does not verify the data that it collects from other agencies. The five 

selected agencies that we collected data from also did not have 

consistent definitions of electronics and sometimes reported inconsistent 

information or used inconsistent methods of tracking the disposition of 

used electronics. For example, DOD tracks some items by weight and 

other items by line item. We attempted to resolve inconsistencies in the 

data provided through this effort through follow-up efforts with the five 

agencies in which we discussed how they attempted to collect the data 

we requested and related challenges and limitations. Based on these 
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-12-74 Electronic Waste

conversations, we determined that the data were not sufficiently reliable 

for the purposes of reporting on amounts of electronics disposed of by the 

five agencies and we did not use information collected in the data 

collection instrument on the extent to which agencies used various 

disposition methods.

We also visited the Kennedy Space Center, in Cape Canaveral, Florida, 

and Defense Logistics Agency (DLA) Aviation in Richmond, Virginia, to 

discuss the procurement and disposition of electronic products. We 

selected Kennedy Space Center because it is designated as NASA’s 

Principal Center for Recycling and Sustainable Acquisition. We selected 

DLA Aviation in Richmond, Virginia, because of its role in disposing of 

excess property received from the military services through DLA 

Disposition. We also visited a UNICOR recycling facility located in 

Lewisburg, Pennsylvania, as well as two private electronics recycling 

facilities located in Tampa, Florida.2

To assess the extent to which the July 2011 National Strategy for 

Electronics Stewardship addresses any challenges that may impede 

participation in electronics stewardship initiatives, we examined key 

provisions of the strategy, such as dividing functional and nonfunctional 

electronics, and compared these provisions with existing policies for 

electronics stewardship. In response to our request for information on 

electronics stewardship, FEC program’s manager, officials within each of 

the five agencies, and seven champions for the FEC program provided 

information on the challenges that may affect agency participation in 

electronics stewardship initiatives.

We selected these facilities because 

of their role in electronics recycling at federal agencies. At these facilities, 

we interviewed officials about the procedures involved in recycling used 

federal electronic products and observed the electronics recycling 

process to learn how electronics are safely disassembled and, in some 

cases, processed for reuse.

3

 

2

UNICOR, Federal Prison Industries is a self-sustaining, self-funded corporation 

established in 1934 by executive order to create a voluntary real-world work program to 

train federal inmates. 

In addition, we interviewed officials 

3

We obtained written information on the responsibilities, training, and challenges facing 

seven FEC champions. The FEC program manager currently serves as the champion for 

two of the EPA regions, and the FEC champion for one region did not respond to our 

request for information. 
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-12-74 Electronic Waste

with the R2 and e-Stewards recycler certification programs,4,5

We conducted this performance audit from October 2010 to January 2012 

in accordance with generally accepted government auditing standards.

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

the 

Electronics TakeBack Coalition, and an electronics recycler to determine 

the extent to which recyclers in the United States have obtained 

certification and to discuss their views about the capacity of certified 

electronics recyclers located in the United States.

 

4

The Responsible Recycling (R2) Practices is a set of guidelines for accredited 

certification programs to assess electronics recyclers’ environmental, worker health and 

safety, and security practices.

5

The e-Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment 

was developed by the Basel Action Network and is the basis for electronics recycling 

companies to become certified e-Stewards recyclers. 
Appendix II: Comments from the 

Environmental Protection Agency

Page 35 GAO-12-74 Electronic Waste

Appendix II: Comments from the 

Environmental Protection Agency
Appendix II: Comments from the 

Environmental Protection Agency

Page 36 GAO-12-74 Electronic Waste
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 37 GAO-12-74 Electronic Waste

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

In addition to the contact named above, Diane LoFaro, Assistant Director; 

Elizabeth Beardsley; Pamela Davidson; Stephanie Gaines; Deborah 

Ortega; Ilga Semeiks; Carol Herrnstadt Shulman; and Vasiliki 

Theodoropoulos contributed to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 38 GAO-12-74 Electronic Waste

Green Information Technology: Agencies Have Taken Steps to 

Implement Requirements, but Additional Guidance on Measuring 

Performance Needed. GAO-11-638. Washington, D.C.: July 28, 2011.

Data Center Consolidation: Agencies Need to Complete Inventories and 

Plans to Achieve Expected Savings. GAO-11-565. Washington, D.C.: 

July 19, 2011.

Electronic Waste: Considerations for Promoting Environmentally Sound 

Reuse and Recycling. GAO-10-626. Washington, D.C.: July 12, 2010.

Federal Electronics Management: Federal Agencies Could Improve 

Participation in EPA’s Initiatives for Environmentally Preferable Electronic 

Products. GAO-10-196T. Washington, D.C.: October 27, 2009.

Electronic Waste: EPA Needs to Better Control Harmful U.S. Exports 

through Stronger Enforcement and More Comprehensive Regulation. 

GAO-08-1044. Washington, D.C.: August 28, 2008.

Electronic Waste: Strengthening the Role of the Federal Government in 

Encouraging Recycling and Reuse. GAO-06-47. Washington, D.C.: 

November 10, 2005.

Electronic Waste: Observations on the Role of the Federal Government in 

Encouraging Recycling and Reuse. GAO-05-937T. Washington, D.C.: 

July 26, 2005.

Related GAO Products

(361226)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (www.gao.gov). Each weekday afternoon, 

GAO posts on its website newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Please Print on Recycled Paper.