Certification and EPA enforcement may turn out to be the holy rain that washes away the sins of the recycling industry and brings the world into happy and holy compliance with the environment.
In the meantime, as a former environmental regulatory official, let me offer a couple of mud boots.
1) Civil Law: Get your e-waste recycler under contract. Better yet, use an existing state contract, enforceable by your state Attorney General, and incorporate your contracts by reference. Better than that, get your state officials to hire WR3A to help them write their state contract.
2) Due Diligence: We recyclers get 40 page RFPs (request for proposals) to do one day events on a Saturday at the parking lot of the suburban such and such. It is a lot of work to fill out a whole proposal for a one-day event, and a lot of work for the Suburban Recycling Coordinator to write and actually vet such a document. So here is a reminder of a tried and true formula for culling the herd of ewaste service providers:
- CRT Glass Test. Bad CRTs remain the bulk of the weight, the bulk of the cost, and the bulk of the toxics in all used electronics. The wicked savings by NOT hiring a guy to NOT inspect the monitor or TV and to NOT pack it carefully to reduct damage and NOT get environmental insurance to NOT properly break and recycle CRT glass and NOT transport it to a lead silica furnace, usually at least a quarter the way around the globe and often halfway... Well, the savings are wicked.
- Printed Circuit Board Test. If you claim that all the PCs are "functional" and "repairable", then you didn't need to hire anyone to disassemble the PCs and remove the boards. Ca-ching.
- Employees per ton. Not hiring people to inspect and remove the non-repairable and obsolete equipment? No demanufacturing? No department of labor worries.
- Sea Containers per ton. Baled, demanufactured, clean scrap takes a LOT less space than loose used electronics. And obviously, the less bad electronics you remove from the sea containers, the more sea containers you need.
WR3A now has a vetting program (click "find a recycler") which automates these tests, and with funding we will be able to check the data via at least 4 sources, one for each "test". Our experience so far? Falsely submitted data shows up funny on the scattergram, and at least one external source "outs" the liars... but usually the companies we are pretty sure are exporting everything don't click to pay $350. They see where this is going.
If we get the "Certification Scholarship" underway, we will have tens of thousands of dollars to pay auditors to get even deeper into the walls of the recyclers. The 4 tests might be retired. But until then, remember to ask "where's the beef?" Simple questions are best left answered.
More to come. Stay tuned.