My Contribution to EPA CRT Cullet Discussion

This was my comment to the organizers and regulators in the meeting about CRT Cullet Markets (see agenda at bottom):

We were involved in the sale of CRT cullet from an alleged "pile" in the southwest which was widely speculated to be non-moving.

Cullet from the pile was sold (not through us but using our smelter's same trucking company) to a lead smelter in Mexico, which paid 7 cents per pound.

After the 2010 SEMARNAT border controls on the CRT cullet, the Mexico lead smelter said the material was a "headache".  They changed in 2012 to charging 7 cents per pound instead of paying 7 cents for the exact same material.  That is a change of 14 cents per pound based on nothing but "diligence" which equated (to the mining/primary smelting company) as "risk".

This discussion is inadvertently creating justification for companies which speculate on whole tubes, avoiding the cutting and washing.   EPA needs to clearly distinguish between diligence on whole unprocessed material and companies which have turned that material into saleable commodity.

A shredded toaster (steel pieces) should not carry a label of "toaster waste".  It's ferrous metal.  The CRT glass which has been processed should be treated as leaded silicate, and governed by MSDS and DOT etc. according to its properties, not as a "waste".

When we exaggerate the risks of "waste" (attributing more weight to the risk of human-generated secondary material) compared to the risks of identical or higher-risk "virgin" material, we set up bad regulation.  The regulations we have established for "Cathode Ray Tube" glass penalize a smelter if they try it as a feedstock.

The culprit, ironically, may be the word "Stewardship".

lead mining of yore

When we mine gold, copper, tin, iron, tantalum, silver, etc. from mountainsides and Indonesian coral islands, we do massive damage on several scales.  Endangered species are exposed by access roads.  Children mine coltan to fund warloards.   And the number one and number two sources of mercury in the USA are not mercury mining - they are gold and silver mining.   The mountainsides release radioactive uranium, leaded dust, mercury, etc.   Fourteen of the fifteen largest Superfund Sites in the USA have been hard rock metal mines.   But the mountain is not a "Steward".

We still govern mining based on the General Mining Act of 1872.   How can recycling compete with standards of yore?

Listening Live to the Consumer Electronics + EPA + ISRI Conference Call on CRT Glass

It's slowly coming across.

1)  Is there a risk?  

The concept of "speculative accumulation" was created because, while commodity status can be used to keep waste regulators at bay, there is a risk that the material is bound to become waste.  When it's a very expensive to manage and dispose-of material (say radioactive waste, or highly toxic mercury), there needs to be an avenue for regulators to step in if it's a disaster in the making.

However, what if there is no risk?  Steel and scrap paper are accumulated, copper is accumulated, gold speculation is rampant.   I have a television here in the house I don't watch much... I'm speculating it may be an antique someday and I'd like to keep it.

The TCLP test was misapplied to begin with.  CRT glass has vitrified lead, lead that does not leach out.  It's like the lead in leaded glass cyrstal.  There is no risk to it.

2)  By regulating it as if it's a risk, are we scaring away markets?

Absolutely.   The silicate and lead are positive revenue materials, and there are dozens of smelters which would accept these commodities if they were offered on the basis of their chemical properties.

The mis-application of the CRT Rule has created a false need for assurance.

3) Have we hobbled CRT cullet with rules that mined material doesn't have to follow?

You got it.

Jack Johnson, the Galveston Giant (Better Together)

History Channel:   I've learned about Jack Johnson, an African American professional boxer who was finally allowed to fight a white champion, Tommy Burns.  See also the Ken Burns documentary on PBS, titled "Unforgivable Blackness". He's in the news again (last month), for a congressional request to Barack Obama to grant Jack Johnson a pardon for his phoney conviction.

US Library of Congress

Both History Channel and Wikipedia link concern about Johnson's interracial sexual partnerships, and fear of his dominance of the sport, with the passage of the Mann Act. The Mann "White Slave" Act made it illegal to transport a prostitute geographically across state lines.   According to Wikipedia:

The White-Slave Traffic Act, better known as the Mann Act, is a United States law, passed June 25, 1910 (ch. 395, 36 Stat. 825; codified as amended at 18 U.S.C. §§ 2421–2424). It is named after Congressman James Robert Mann, and in its original form prohibited white slavery and the interstate transport of females for "immoral purposes". Its primary stated intent was to address prostitution, "immorality", and human trafficking; however, its ambiguous language of "immorality" allowed selective prosecutions for many years, and was used to criminalize forms of consensual sexual behavior.^[1] It was later amended by Congress in 1978, and again in 1986 to apply only to transport for the purpose of prostitution or illegal sexual acts.^[1]

According to the History Channel documentary, the passage of the Mann Act in 1910 coincided with Jack Johnson's peak years, and specifically with Jackson's defeat of great-white-hope champion James Jeffries.  Race riots resulted.  Blacks celebrated, whites tried to stop the celebrations, people got killed.  It was the top news story the year the Mann Act was passed.

How to solve a problem of competition?  With racial discomfort and fear-based overreaction. 

 In addition to his punishing victories, however, Johnson was known for his extravagant lifestyle, and was excoriated by his white critics for his romantic relationships with white women. In 1913, Johnson was convicted (in what was widely considered a sham trial) of violating a federal law, the Mann Act of 1910, which outlawed the transportation of women across state lines for "prostitution, debauchery, or for any other immoral purpose." He was found to have traveled with his second wife, a former prostitute, across state lines before they were married.

That's right.   The 2010 Mann Act law against transporting prostitutes across a state geographical border was used to arrest Jack Johnson for driving his wife, a white woman, and ex-prostitute.   The courts found him guilty because he had driven her across a state border before they were married, in 1908.. Two YEARS BEFORE THE MANN ACT WAS PASSED!  

What does that remind us of?  How about the Basel Ban Amendment, which still hasn't been passed, which is described as some kind of a limit for transboundary export-for-repair, in today's trade journals?

Geography, protectionism, racial segregation... greed and fear... cognitive dissonance.    What's the root story?   Out of fear of competition, blacks were banned from boxing whites in the USA.   When Jack Johnson found a venue (Sydney, Australia) to meet and defeat the white boxing champion, and used his winnings to celebrate with white women prostitutes, whites tried to find a white hope to shred Jackson in the ring,  But the undefeated champion Jeffries, allowed to box Jackson in Las Vegas, would lose in 1910.

Should we stop White Slavery?  Of course.  But was it really a problem in the first place?  Or was it a way to rationalize interfering in relationships which bothered us for the wrong reasons?  People like Jacksons wife are described as victims, transportation is observed.   It doesn't add up to a crime.

More Insider Dope on Electronics Export Transactions: Giovana Vitola

Leyla Acaroglu tweeted us about a documentary, aired in Australia, as proof that electronics exports are bad.  The reporter is a Brazilian woman, who is now in Singapore.   I have an address for her to visit.

Giovana Vitola's documentary "E-Waste Hell"  (shown on Australia's DateLine) follows the Basel Action Network recipe.

1.  Fly to a big city in an exotic location.

2.  Find bored kids burning TV devices (and refrigerators) at a city dump.  Take film.

3.  Interview an African (Mike Anane) who reads and believes BAN's fake 80-90% export statistics.

4.  Go to the sea container yard and take pictures of televisions being unloaded (from Australia)

5.  Interview the importer with a hidden camera.

Before you assume this is "same old same old", watch the documentary all the way through.  I noticed a few things worth talking about.

First, the standard freeze frame screen shots show, once again, that the devices filmed in the landfill shot look nothing like the flat CRT (2003ish TV year, which would have been made a the Samsung Corning flat CRT furnace in Klang, Malaysia, which made the compact CRTs until 2011).  She films one with broken plastic, but it's clearly shipping damage, and it's cosmetic, it doesn't mean it won't work.

No, I don't think so.  Talk to StEP much?

Second, the undercover film shows what Interpol recognized in its 2009 "organized crime" report.  The sea container is being received by the family business... the importer says his brother lives in Australia, and bought the televisions.  Another "Hurricane Benson" being associated with the dump, kilometers away.

Interpol:  Brothers + buying = organization = mafia