2002 Roadmap for E-Waste Export

This is where I met BAN and tried to work with them from 2002-2006.   They seemed to appreciate the facts and prices.  I thought it was worth reposting.  It's dated, especially the reuse prices, but it makes a lot more sense than any statistics or research the anti-export lobby has put out.

Exports of Scrap Electronics - Situations, Principles and Standards

Boston Globe's Murky E-Waste Reporting

The Boston Globe (reporter Beth Daley) was the largest paper to pick up the story that BAN.org circulated, alleging that recycler CRT Recycling (CRTR) of Brockton illegally exported TVs for dumping to Indonesia.  

As I have reported in this blog, there is certainly an opportunity for unscrupulous recyclers to ship junk they must otherwise pay for.   But the factories overseas have no incentive to pay for that junk, and they are certainly not "backyard" operations.

The problem here is that the Globe (in an editorial below) has now elevated the BAN allegation, effectively confirming that the containers were bound for dumping. They did so without looking.  The containers have arrived back in the port of Boston, still under seal.  EPA has been inspecting the containers and is probably withholding judgement until they are inspected.  I would hope so.

The Globe however did not make the mile trek to the port of Boston to see for themselves.  We shared film of some of the Indonesia factories with the Globe, and I can understand how the Globe may not have the budget to fly reporters across the world.  But the containers are in the port of Boston.

CRTR prices have driven me crazy for years.  Other recyclers are jumping for joy that the lowest bidder out there is caught in an enforcement action.  But I have to ask, what if these were MY containerloads, which I had exported to a legal, permitted, audited, ISO14001 factory?  What if BAN sent a letter to the government of the importer, telling them my containers were 80% waste, and the country returned them back to me, under seal?  How would I feel if the Globe alleged inaction by EPA based on a false accusation, while EPA finished its inspection?   I would probably feel like one of the USA state departement employees accused of being a communist by Senator Joe McCarthy.   Where is a Senator Millard Tydings when you need one?

It is unfair that I am in a position of defending an arch competitor, who may or may not be guilty of shipping junk, based on shoddy journalism.   My ideal self says that CRTR, the EPA, and the factory in Indonesia CRTR shipped to, all deserve an actual investigation by a real life journalist, and that the proof will be in the numbers - how many pieces in the containerload, if any, were junk, and what happens if junk arrives in Indonesia?   That is the story that has yet to be told, that is the question the Boston Globe has yet to ask.

GLOBE EDITORIAL

Quit dumping old TVs overseas

March 10, 2010

THE MURKY afterworld of dead electronics was brought home this winter when a massive shipment of old televisions from Brockton’s CRT Recycling was rejected by the government of Indonesia and returned to Boston. Old cathode ray TV tubes contain several pounds of lead, mercury, cadmium, and other toxins. The blowback from Indonesia is evidence of why the US, the world’s largest producer of electronic waste, should sign the Basel Convention that bans dumping in developing countries. The United States’ own Government Accountability Office says American regulations are “among the weakest in the world,’’ allowing a “virtually unrestricted’’ flow of old TVs and computers to the Third World.

My response:

"Murky" is a good word, in that it cuts both directions. The Editorial is murky, the allegation is murky. Where are the facts? There is a factory refurbishing TVs in Indonesia, there are several such factories. There is an opportunity for an unscrupulous exporter to mix bad and unrepairable TVs into loads shipped for those factories. The CRTR containers arrived back in the USA in sealed containers, neither the environmentalists nor the Indonesian government opened the containers to see what kind of TVs are inside. They are here in Boston. This is your opportunity to find out the truth. While I am a competitor of the company in Brockton, and do not like the prices he competes at, I am shocked that the Globe would reprint the allegation when the nation expects you to be there and to look at the containers, and beyond shocked that the Globe would elevate this to the Editorial section. You have formed an opinion that the load was not as CRTR represented and that the refurbishing factory is a "backyard" operation, when you have an invitation and film to view.  That is indeed murky journalism. Several journalists who have reviewed the initial press release paused in their coverage and are willing spend the time the Globe is not willing to spend to see the operation in Indonesia, look at the records of the containerloads of used electronics, and report the truth. If the Globe's opinion turns out to be right, consider yourselves lucky. If you are wrong, consider yourselves "murky" rumor repeaters, not reporters. You have up until now reported nothing but an allegation, and have done nothing to investigate it.
--
Robin Ingenthron

Basel Convention Doesn't Say That. Does too. Does Not. Does so too.

What DOES the Basel Convention say about Export for reuse, repair and refurbishment?  This is Annex IX, B1110, which specifies "what is the good stuff", the language describing those things that are definitely not banned for export under Basel Convention (which USA has not ratified anyway).

"B1110 Electrical and electronic assemblies:

• Electronic assemblies consisting only of metals or alloys

• Waste electrical and electronic assemblies or scrap⁽¹³⁾ (including printed circuit boards) not containing components such as accumulators and other batteries included on list A, mercury-switches, glass from cathode-ray tubes and other activated glass and PCB-capacitors, or not contaminated with Annex I constituents (e.g., cadmium, mercury, lead, polychlorinated biphenyl) or from which these have been removed, to an extent that they do not possess any of the characteristics contained in Annex III (note the related entry on list A A1180)

• Electrical and electronic assemblies (including printed circuit boards, electronic components and wires) destined for direct reuse,⁽¹⁴⁾ and not for recycling or final disposal⁽¹⁵⁾

14. Reuse can include repair, refurbishment or upgrading, but not major reassembly.

15. In some countries these materials destined for direct re-use are not considered wastes."

This pretty clearly says that CRT glass is bad if it is not exported for reuse, repair, refurbishment and upgrading, but that if it is for those re-uses, that it is not an illegal waste.  

BAN has said that I am not qualified to read or interpret this.  When I have said we have legal authorities from overseas nations who agree with us and grant import permits in writing, BAN says to tell them who they are so that BAN, the small Seattle NGO, can write to them and dissuade them.

Here is BAN's argument (regarding MPPI, the mobile phone issue).  Please read it.  In my opinion, it's extremely not entirely very clarifying, but in their own words is best.  Here is why the Convention actually says "tested working" and "no export for repair", according to Basel Action Network.  

BAN's protest of this definition.

Someone needs to not pretend these guys know what they are talking about.   I can grab the Doha round and start a non-profit around that obscure international treaty, and form a consensus around my protest opinions, based on the phenomenon that no one else reads it.  This is insane.

Three Good Ideas for "Solving E-Waste Problems"

One of the downsides to battling well-intentioned bad ideas (the export prohibition legislation) and to pushing back on holy men like BAN's Jim Puckett is that making the NGO's idea controversial also taints with controversy the better ideas which you need the NGO's support on.  


Unfortunately, it has now been a decade since I began promoting the three good ideas below.  After 10 years, no one shows interest.  I get an occasional glimpse of "oh yeah, I remember that" from some state and federal officials.  Now that I am going ninja on Basel Action Network (in response to their deliberate attacks on good foreign operations), I would like to find another NGO to replace me as the chief advocate for three ideas BAN gives lip service to but which need to be raised.


These 3 Great E-waste Ideas babies are floating down the Nile...  (psst!  Miriam!  Wake up!)


1)  SPARE TIRE OS LICENSE.    Instead of making MAR refurbishers pay $5 for a MAR license, get the original buyer of the product to buy a second "spare tire" license.  See page 8 of this 2000 EPA JTR Report on the recycling infrastructure in MA, search "spare tire".  Fabulous idea.


EPEAT could do this.  When a state or federal or corporate buyer orders $20M in new PCs, they can ask for a second MS license to be affixed to the side of the computer (like the OEM licenses of old).   When their PCs are decommissioned, the IT people could take the PC online and enter in a password and a remote wiping code, reinstalling the new Microsoft Windows or other license.  Now any used PC would have a legal license.


The economics are win-win-win.  The cost of an OEM license relative to the cost of the new PC is maybe $10 to $400, or 2.5% of the purchase.  By comparison, the cost of a $5 MAR license is to a $50 used PC is 10%.  The OEM version does not really compete with re-installations and bootlegs that the MAR refurbishers do.   Finally, the OEMs who negotiate a Microsoft OS license down to $10 would be in a position to pay even less for the second license - maybe $11 for two licenses per machine.  Microsoft wins because it gets paid for the "MAR" license up front (3-4 years cash flow) and is collecting an extra dollar on some machines that will never even get refurbished.


2) MINING CLEANUP = RECYCLING CREDITS.   The General Mining Act of 1872, which leases for $5 per acre federal lands for mining (and polluting - those mines become Superfund sites, a doubling taxpayer jeopardy on each "land lease").   


The cleanup of the mining sites ($1.5B settlement with ASARCO, e.g.) is going to be money down a rathole, they are not going to be able to clean up those sites by sending Haliburton men in moon suits with mops.   Instead the money should go for alternative mining - mining of urban ore - ewaste recycling programs in the communities which suffered the pollution.   An even better idea is to reform the General Mining Act of 1872 - legislation has already passed the House of Representatives - and increase the royalties on metals from 0% to something percent and have part of that money go to e-waste recycling.   There is probably a danger that this money will be used like SB20 money to destroy reuse (obsolescence in hindsight) but if there is a competitive bidding we may be able to control that.


3)  RECYCLED CONTENT GOLD.  I already orphaned this idea in June 2009 by dropping my patent application.  When I dropped the patent app, it did not take long for someone to promote the idea with these Olympic medals.  The problem is minimum content has not been defined well enough.  If we set up a program to restrict the claims to significant percentages of recycled gold, recyclers will benefit more and that money will go to getting more e-waste out of the waste stream.


These are the best ideas being discussed in E-Waste right now, if I do say so myself.   I declare them orphans.  I have two other fabulous ideas which I intend to become a millionaire with.

Meet the E-Waste Criminals

We have hours of video of all our our export partners, which we used to make some 3 minute films for Fair Trade and WR3A.  The first here is just a preview of the hours of interviews, I just grabbed clips from Burkina Faso, Cameroon, Egypt, Indonesia, Malaysia, Mexico, Nepal and Peru to give an idea of the "Geeks" who are working together.



These are not nameless, faceless, Viet Cong polluters.  These are the smartest kids from their schools, who in the USA would be applying for engineering programs at MIT.  In the countries where they were born, buying and repairing and selling computers is something they can be proud of.  Most of the ewaste they see is "home grown", but if they get a chance to get some really nice stuff from rich countries, it is a boon to them.

The truth is hard to massage into clips and sound-bytes.  I think "Fair Trade" works.  But it is hard for an agent of conscience to find the right pitch, to slow the train set in motion.  We have been sold a simplistic "export is waste" story, which served a legitimate legal purpose in reforming E-waste export practices ten years ago. 

At this point, the fear of exporting "toxics" has demonized the best and brightest in the developing world, taken food from peoples mouths, and taken computers away from blood banks.  It is out of control.   As we would desire and expect, the United States EPA took all of this kind of information in and drafted a CRT Rule which was intended not to throw the baby out with the bathwater, and EPA formed a group of experts from NGOs (BAN, WR3A, CTBC, etc), manufacturers, non-export USA Ewaste processors, and reuse and recycling processors who export.  They drafted a set of rules for Best Practices called "R2". 

EPA is being attacked, the International Geeks are being attacked.   I find myself increasingly writing "Malcom X" blogs, because my "Martin Luther King" approach is getting nowhere.   The people in this video, the people from overseas, were not represented by anyone but BAN and me at the R2 meeting.  I am willing to set up tours from any journalist or reporter who wishes to "meet the exporters".  We will show you everything, the good, the bad and the ugly, the entire Heronimous Bosch fresco of recycling and refurbishing in the developing world.  It is not perfect, but when you meet the human beings that I meet and deal with, whom BAN has never spoken to, you will see what Micro Lending and Kiva sees.  People who are who they say they are, and do what they say they do, who are trying to drop their buckets where they are, and who lift as they climb.   This is not just about the environment, this is about development, and telling the truth about human beings who have no seat at the table and cannot defend themselves.

Way back, my Freeland relatives and Dewards lived in Vermont before the civil war.   They moved to Kansas to vote in the "free or slave state" elections, following the Missouri slave state vote which upended the Mason Dixon compromise.   I have often wondered if I would have had the guts to follow John Brown.   This experience, being the only electronics recycler to stand up to BAN, is perhaps in my genes.  

Basel Action Network's legacy - stagnation and poverty?

Is the solution to poor coffee farmers to take away their coffee business?

Is the solution to poor recyclers to take away their recycling business?

Is that the best we can do?  The people remain, we just remove "recycling" as the verb.

From Cairo Tour 2008

Folks, it is looking grim.  The U.S. Congress is currently debating whether to pass H.R. 2595, which would ban the export of any device not tested and certified as fully operational. Since the Basel Convention doesn't actually SAY "tested working" or that refurbishing businesses are illegal in developing countries, the new tactic is to get governments to call used computers "waste".  The same companies who brought us "planned obsolescence" are licking their chops, as laws are passed to do their work for them. Most "hindsight obsolsecence" laws are being passed in developing nations themselves, where officials are so fearful of the myth of toxic ewaste that they are denouncing their home grown techies, the Michael Dells of Africa and Asia, and banning even working units from import.

We are likely to lose the fair trade battle.  I have met with ambassadors, import businesses, and African Entrepreneurs.   Despite the films WR3A  has made, and the efforts we have promoted to make "fair trade" possible, the continent of Africa is increasingly accepting the BAN approach of a ban on imports.  (BAN has alternately said they are in favor of export for reuse and refurbishment, but is continuing to promote the phrase "tested working", and is taking no steps to convince either Africa or their E-Stewards that is is ok to export intact units).  The few E-Stewards who are exporting intact units at all should watch BAN's game in Africa and Asia, because the tested working market is being closed as well.

Since the closure of our repair partner programs in Senegal and Cairo, I have gotten desperate, even angry at BAN, for continuing to promote the myth that 80% of exports are junk.  That defies environmental sense, defies economic sense for the importer, and defies the photos and film the NGOs themselves are producing.  The films of containerloads being emptied show nice stuff.  They have to go to the dump to show bad stuff.

The bad stuff goes to the dump.  Is it 20%?  30%?  5%? - it depends on the exporter, and only WR3A members are able and willing at this point to disclose those numbers.   If it is a good company exporting, it's a little bit of junk (accidental breakage, removed parts).  If it's an uncaring company, it can be 30% and higher.

But now Cairo is shut down (we are refurbishing to like-new condition in Asia to supply Egypt), and here is a story from Kenya, announcing the shutdown of all used computer imports, working or not, into the whole country.  The same article shows a poll that Kenyans cite internet almost as high as cell phones as technology they cannot live without. 

Kenya's Saturday Nation, March 5, 2010

The Ministry of Information and Communication is proposing a ban on importation of refurbished computers in the next budget to reduce e-dumping in Kenya.

Permanent secretary, Dr Bitange Ndemo says that Kenya, like other African countries, has become a dumping ground for used machines.

“It has become big business for the foreign companies we import from as some are paid by their governments to amass the dumped electronics, refurbish and sell them to us,” said Dr Ndemo.

Ok Jim, you win in Egypt, you win in Kenya.  So let's complete the vision for those countries development.  Your hope is that they will "leapfrog" the west.   Bring it on.  Let's see the "leapfrog".  Where are the new computers?  That's the solution, right?  The Kenyans should "leapfrog" and get new computers.  What a great vision.  
The African continent can skip right over the repair, refurbish, reverse-engineer, knock-off, contract assembly, and manufacturing evolution that southern China, Signapore, Korea, Malaysia, Taiwan, India (and even 1800s USA) followed on the path to development.   We can throw out the UNCTAD reasoning, that recycling is inherently better than mining and should be cleaned up and reformed.

We can destroy the Zabbaleen's sorting stations, kill their pigs, and close down the informal recycling programs in Cairo.  We can ban the Indonesian CRT assembly and manufacturing factories which turned to refurbishing cores (CRTs) to save their factory jobs, like Cummins Engine in Memphis Tennessee did. See Indonesia rejects CRT shipments to Refurbishing Factory

If Fair Trade loses, who wins?   There are roughly 3 billion people earning about 3 thousand dollars per year who, for the past decade, have gotten access to the internet at 10 times the rate of the USA.  Even a $60 computer is extremely expensive to them.  But Basel Action Network has sold the vision, and the refurbishers are shutting down. So now they can now leapfrog us.  Their national development should not bear the indignity of checking email on (gasp!) a CRT screen.   3 billion LCDs (which last 25% as long as a CRT life), coming right up!  Ready, set, go!

Instead of protesting the mining of raw materials for electronics in Africa, like the coltan for cell phones (which has decreased the population of lowland gorillas by 60%), western NGOs like BAN have chosen to protest reuse and recycling, the only alternative to that mining (other than stagnation and poverty).  They hit a nerve among the conscientious in the recycling community.  And it is certainly true that there were plenty of bad actors mixing in "Toxics Along for the Ride". 

For several years, BAN did a good job of improving our industry by keeping us on our toes.  But today's article from Saturday Nation in Kenya is Sarah and Jim's prize.   The UN program I have been meeting with had a plan to put 500,000 internet computers into Africa this decade.  But the only way to afford that was with CRTs (which don't get stolen, are built like battleships, are repairable) - but used CRTs, working or not, are being made illegal to import used.

Meanwhile, independent university research into the issue indicates that WR3A and Fair Trade programs are on the right track.  A new study from ASU is appearing Mar. 22 in Environmental Science and Technology, which seems to blow apart the theory that ewaste export prohibition would clean up ewaste dumps overseas. The study estimates global generation of obsolete computers, with these results:

• By 2016-2018 the number obsolete computers generated in the developing world will exceed that in the developed world,
• Global volumes of obsolete computers are expected to triple between 2010 and 2025,
• By 2025 the developing world will generate double the developed world’s waste computers.

[ASU]'s results fan the debate on how to deal with backyard recycling. Trade bans, he argues, will become increasingly irrelevant in solving the problem. The study’s authors suggest that direct policy action to address the environmental impacts of informal recycling is needed. Policy should also consider the considerable economic and social benefits of refurbishing electronics for reuse in the developing world. 

Who will manage the "home grown" recycling, as developing countries produce their own WEEE and e-waste?  In the USA, electronics geeks like Dick Peloquin and David Cauchi pioneered proper e-waste recycling practices.  One of the first thing Retroworks de Mexico did was estabish a "cash for clunkers" program to get ewaste off the streets of Sonora in Mexico. Our refurbisher in Malaysia is now the CRT recycler for schools and communities there.  But the same fair trade improvements made in Senegal and Egypt are now shut down.   With HR 2595, which BAN applauds, we will shut down the factories in Malaysia and Mexico next.

Jim, you wrote a comment on a past post that the dialogue was over, you were not speaking to me anymore.   It's all going according to plan, so why listen to criticism?  I'm sure you have a great answer to these questions.  You say that 80% of the exports are "junk" and that our processes are illegal because "a part may be removed during the repair, which is then waste".   

So are you saying the capacitors the techs may replace are 80% of the load?  Look at the tech in Egypt (at top) whose job is gone.  Did he really repeatedly pay for 80% junk?  Is his circuit board repair so polluting that he's better off spending three month's income on a new PC made from mined materials?  I confess, we did not remove the tiny little capacitor that he bypassed.

The Indonesia factories (left), BAN says to the press, are illegal because 80% of the material they import is waste to be burned.  But what BAN's director says to us, when we described the factory, is that the upgraded pieces (even if later properly be recycled), were technically waste because they were not removed prior to transport.  

Almost the same thing, I guess, 80% of the containerload is junk, or some pieces removed during a repair and properly recycled are "technically" waste.

BAN has momentum, they are going to win.  They will shut down these poor overseas techies and geeks I deal with, the valedictorians and heros of their schools, by throwing them in the boat with copper wire burners.  But they are making up a story about the med school students "leapfrogging", while treating these technicians like Joe McCarthy treated the "commies".  They take pictures of junk and lead journalists away from the refurbishing factories (showing CBS 60 Minutes stacks of CRT monitors in Hong Kong and leading them to Guiyu, where there is not a single CRT factory - or a single CRT in sight).  And gosh, they are winning.  But whatever happens to my friends and their businesses, history is going to get out.  BAN had better come up with some solutions, either leapfrogs or fair trade reforms.  If Jim Puckett counts the Kenya, Egypt, and Indonesia import bans as successes, but does not replace the affordable electronics, he will go into the history books as the Ayatollah of E-waste.  When the perfect becomes the enemy of the good, both will fail.

Any Questions?

Dear BAN,

The factories you refuse to allow E-Stewards to sell good CRTs for refurbishment to are the same factories that you bought your CRT monitor from.

Any Questions?

(I think it's called "manufacturer take-back")