Panel

1
Panel 4 Role of Producers in the EPR System

• The National Electrical Manufacturers Association
  
• Monica Roll Duracell
• April 28, 2008

2
Manufacturer Role

• The manufacturers role must start with, and
  feature prominently in, the policy-setting
  process
• We know our products best
• Specific to California, we believe the
  manufacturers role is to bring valid, scientific
  information to the debate regarding
• Relative risk of batteries in landfills
• Environmental and economic benefits and tradeoffs
  of collection /recycling systems vs. landfill
• Battery manufacturers goal ensure EOL policy
  related to batteries is beneficial, affordable,
  and sustainable

3
Existing Studies Provide Valuable Evidence

• Fukuoka University Landfill Study 1987 to
  present
• Waterloo Risk Assessment Study 1992
• University of Liege Faculty of Medicine, Belgium
  1994
• UK Department of Trade and Industry 2000
• Solid Waste Association of North American (SWANA)
  2003
• French Environment Ministry Principal Research
  Agency Efficiency of Battery and Accumulator
  Procedures (2006)
• UK Department of Environmental Study 2006
• However, none of these studies were conducted to
  current U.S. conditions

4
Manufacturers Sponsoring New Research

• Three Scientific Investigations Underway
• Comprehensive Review of International Scientific
  Literature
• Simulated Landfill Study (Lysimeters)
• Economic Environmental Impacts of Alkaline
  Battery EOL Strategies (i.e, LCA)

5
Literature Review

• Critical Review of the Literature Regarding
  Disposal of Household Batteries Completed Dec
  2007 (186 pgs)
• CalRecovery, Inc. in association with Den Boer
  Waste Consulting, GER Fukuoka University, JAP
  IMAGE, University of Padova, IT Univ of Central
  Florida
• Covered English, German (incl. German, Austrian,
  and Swiss), Dutch (including Holland and
  Belgium), Polish, Italian, Japanese, Korean,
  Spanish
• Few studies in most languages Those that exist
  do not suggest household batteries are hazardous

6
Simulated Landfill Study

• To evaluate behavior of alkaline batteries under
  simulated landfill conditions
• CalRecovery, Inc in association with Hamburg
  University of Technology
• Portrays solid waste landfill environments using
  laboratory-scale reactors (Lysimeters)
• Size-reduced, cut batteries are placed in
  reactors modeling typical, intensified, and
  worst case LF conditions

7
Simulated Landfill Study (Contd)
8
Simulated Landfill Study (Contd)

• Solid waste in reactors reflects CIWMB profile of
  Calif overall disposed waste for calendar year
  2003
• Long list of parameters to be measured incl
  metals (As, Ba, Cr, Cd, Cu, etc) plus pH, eH, and
  gases (e.g., CO2, H2, N2 )
• 1st Quarterly report submitted shows project on
  track

9
Life-Cycle Analysis Study

• Economic and environmental impacts of alkaline
  battery end-of-life strategies
• MIT Materials Systems Laboratory Center for
  Transportation Logistics
• Study has two main components
• 1. Analysis of Baseline Scenario (alkaline
  battery disposal), and
• 2. Analysis of Recycling Scenarios.
• Will employ modeling, data collection, metric
  development, and sensitivity analysis.

10
Life-Cycle Analysis Study (Contd)

• Study will address following questions
• What are the economic and environmental impacts
  of different end-of-life strategies for alkaline
  batteries in the United States?
• - Strategies Disposal and recycling
• What are critical factors affecting impacts?
• How do impacts of recycling vary with collection
  scheme?
• Final result Map of conditions under which
  recycling can be economically and/or
  environmentally favorable

11
Life-Cycle Analysis Study (Contd)
Does Benefit Outweigh the Burden?
12
Conclusions

• CIWMB framework is to address products that have
  significant impacts on the environment.
• Existing scientific evidence does not suggest
  alkaline batteries are in this category the
  industry is working to further resolve that
  question
• There is evidence to suggest that separate
  collection recycling may actually have adverse
  consequences
• Manufacturers are providing Life Cycle Assessment
  information that will answer these critical
  questions specific to California

13
Recommendations

• Defer action on alkaline batteries until
  state-of-the-art studies are complete
• Unfunded mandates burden all in the system, and
  should certainly not be undertaken without a
  thorough understanding of the ultimate impact
• LET SCIENCE AND FACT DICTATE POLICY
• Manufacturers will partner with all relevant
  parties to ensure a sound solution and will
  strive to bring facts and data to a constructive
  debate