E-Waste Toxics 101: Commodity or Waste?

Environmentalists need to take a "precautionary principle" towards declaring and labelling things hazardous. How Stuff Works has a nice map of the human brain which specifically locates the source of "Panic Attacks".

We have to manage toxics at our electronics recycling facility. The most important is lead (leaded silica in CRTs), and when we manage lighting (fluorescent lamps), there is mercury. The lead and things like lithium are actually very valuable and are solid and sold as commodities, but if discarded in a landfill they will likely leach into the groundwater. There is a lot of learning we have to do, keeping track of differences between:

a) what OSHA considers a hazard (mainly based on volatility, lead that cannot escape is not a bigger concern whether an item is "new", "used" or "accumulated")
b) what DOT (federal motor vehicle carriers / Dept of Transportation) considers hazardous (caustics, explosives, weight are more important than toxicity), and
c) EPA RCRA definitions of hazardous waste (what a TCLP test will show escapes into the groundwater if left in a landfill). If a lead battery is recycled, it isn't a waste, and the key difference is whether it is allowed to sit in the rain or soak in a landfill.

I am learning about other risks and "qualified" risks. Cyanide is used a lot at mines, but evidently it evaporates and breaks down to a harmless level quickly enough that we should not be concerned it's tipped onto the ground. I have to be careful myself not to cast "alarmist" references to mining (recycling's only true competitor). Similarly, lead CRTs sent to glass smelters are not very volatile - and a heck of a lot better than mined ore they replace.

What really adds unnecessary noise in the system are postings that declare a hazard that isn't even there ("mercury switches" and "mercury gases" inside Cathode Ray Tubes? Not in any MSDS sheet I have found to date). My favorite is when an alarmist lists health food store supplements (copper, zinc, other "dietary minerals") Good Point's warehouse is fortified with Iron, both a commodity and a dietary mineral, though that's not an excuse not o audit its management.

Just as western medicine inherits anecdotes (like hairy palms, crossed eyes, and bad luck caused by salt shakers) that frighten children more than real risks (like not washing your hands), our field (environmental health) has some pretty wacky alarm bells going off. A visitor to my plant demanded to know point blank if we are managing copper here in Addison County. At $2 per pound, I sure hope so.

Much of what an EH&S training should do is to educate employees about what they should really be worried about in a way that adds statistically to their safety and health. At Good Point, I believe the biggest risk is the forklift... people at warehouses around the country get killed or hurt by unsafe forlift operators. But they don't have to take my word for it. We set up employee representatives to filter questions for safety meeting so that no question is scoffed at or made to sound silly, and monthly safety records show which are new concerns and which are ongoing concerns, and (hopefully) documents our efforts (or lack thereof) to find a solution.

What really doesn't help are health insurance companies selling policies charging money to protect us from "hairy palms", or home insurance policies against falling trees in the desert, floods in desert highlands, etc.

To that degree, E-steward standards and legislation that requires actions to be taken against silly threats (containment of dietary minerals, wiping before shredding of 10 year old hard drives), plug-and-play definitions of "functionality" (rather than what the purchaser defines and demonstrates is their own definition of functional) ... recyclers do them because they don't know not to, then want to use the costly and unnecessary practice to raise the level of concern about competitors who just shred drives without wiping them first. Those companies are kind of in the fear-selling, poster-child waving, hyperbolic court which could cause Americans to become cynical about recycling, and about legitimate toxic threats as well.

Risks should be ranked and workforce standards should be based on the most effective ways of bringing the most health to the most employees. While we wait for standards like RIOS and R2 to gain traction, it would be nice to stop the "chicken littles" from screaming about a 4% failure rate of reuse monitors when the process of breaking and recycling them is more dangerous, more expensive, and requires more new monitors to be mined and manufactured. Our industry needs to get on the ball and embrace standard setting organizations like ISRI, OSHA, and WR3A.

#E-waste in Vermont... Steward vs. Steward

In 2001, Vermont communities began holding "one-day events". A nice start, which the rest of the USA wished it followed.

By 2007, events were passe. Most communities had permanent collection programs. Like tires, white goods, auto batteries, air conditioners, etc. a small fee applied. People paid it, by and for all.

In 2009, two Giants came to Vermont to "participate".

One "Steward" went to the communities with long established shared (consumer, municipality, recycler) electronics recycling programs, and said "I'll play too". Sony started to pay for the recycling of all of their products, collected through the ongoing system. No major press, but residents who drove up with a Sony to recycle were surprisedly pleased that it was for free.

The other "Steward" (Samsung) paid an out of state recycling conglomerate to come in and hold "one day" free events. Their recycler is a really good company (though it has virually 0% reuse), and they collected thousands on pounds on a few Saturdays, and vanished. It sent the signal - if you paid before, you were a sucker. If you waited until tomorrow? Too bad.

One OEM program builds upon Vermont's established 84% access program. The other cannibalizes it, taking material and money out of the system. Then they take their subsidies and leave.

The Dell Goodwill program and Staples programs are between the two - not participating in the existing infrastructure, not limited to one day. But no "heavy lifting"... they are taking computer scrap, which Good Point makes money on, and leave the heavy obsolete TVs for the Vermont municipalities to carry.

Here's our plan. If a manufacturer wants to choose an out of state conglomerate, no problem, but please allow the existing infrastructure access to it. Samsung could have had trailerloads delivered to their vendor from Vermont, saving shipping costs. We don't insist on processing our own material. For the Goodwill program, Good Point Recycling has followed suit, offering computer recycling for free, and increasing the costs on TVs. That should, theoretically, allow us to deliver the monitors we collected for free to Goodwill. If their real interest is supporting the infrastructure to include places in VT with no Goodwill (there's only one store in VT), then they should take the computers collected for free in other places, and allow Good Point to deliver them (free delivery). So far, they will accept monitors for free only from our clients, not ones we collect free from our clients.

Meanwhile, as we pass the costs onto the TVs no one is fighting for, it increases the pressure on municipalities to back legislation, like New York's, to pass costs to OEMs. I am not a big believer in putting the Manufacturer (fox) in charge of the reuse market (henhouse). But Good Point also can't be sending the signals to municipality clients that we are deaf to the TV costs being passed down to their residents, as we compete more aggressively for the computers.

You'd think by now, Good Point or the Vermont ANR would have gotten a phone call from Panasonic, Sharp, Toshiba, Samsung, etc. An attaboy, something that says they appreciate that VT consumers and municipalties set up a viable system without them. Maybe recognition that the market they are interfering in has a value. Maybe try to work out a way to participate within it.

Sony is the only manufacturer to dialogue with us. The Samsung program? Like Goodwill, their recycling conglomerate / contractor refused to allow us to deliver Samsung and other product to them, whether or not we took it for free. The national recycling company instead uses the grants to target "free" recycling directly at key Vermont Cities with long established permanent drop-off programs. If Samsung maps where their dollars are being spent, they will see them grouped up in areas where the conglomerate wishes to take over the permanent program. Nothing in Arizona, where TVs are not collected, lots spent where New England recyclers have already set up a viable "shared responsibility" system.

I hope whoever is in charge at Samsung takes a look at how the national contractor is spending their money in a land-grab, to take away tonnage from programs that were already set up without their help. How much did they spend per capita on Vermonters, vs states which have never had an e-waste collection? How many of those Vermonters already had a sustainable, long-maintained, shared responsibility program? How does use of their grant money differ from Standard Oil, offering penny-a-gallon gasoline for six months in the areas they were interested in gaining market share?

Fortunately for us? Anti-trust laws are enforced by the Vermont Attorney General's office.

Trying to keep my powder dry. There aren't really any bad guys in this story, just clumsy people who probably have not thought through the unintended consequences, or at worst don't have a lawyer telling them about the Sherman Act. If they were successful in putting Good Point Recycling out of business, do the OEMs really want me to be blogging full time? Putting us out of work is bad for legislation, bad for access to TV recycling, and bad for the planet. The guys at Sony have been participating in the municipal recycling infrastructure longer than anyone else, since the 1990s. Our shared responsibility, coupon-model, is worth a look.

Joe Truini of Waste News

His Facebook page, running the marathon, captured him well. I never saw a photograph of him boxing.

I just learned that Joe Truini passed away in Akron Ohio. It's strange, I had just out of the blue started to write about reporters who I really admired (see Fialka below), last week. If I'd gotten around to trade news reporters who could use their medium to broaden thinking, Joe would have been one of the first to come to mind.

Joe was someone who always had time to talk, was always listening for a more interesting angle, and really encouraged those of us willing to step out on a limb. He was 37, and I was shocked to hear of his passing, but he was a young man with the heart of a lion.

HP Embraces African Entrepreneurs

This may be the best thing ever, a win for sustainable development. We hope to get a call back from HP, as WR3A wants to help with this project.

WR3A doesn't want to be threatened by successful momentum. We want to be out of a job.

How should WR3A approach the HP Recycling in Africa, UN thing? Is there a Wolf from the Anti Gray Market Alliance still lurking? Or did HP arrive at the Ford Motor Company conclusion?

Ford's response to Vance Packard ("The Waste Makers", book about Planned Obsolescence) was as follows:

1) The more used cars are available, the more affordable "learning to drive" becomes.
2) The younger people are when they learn to drive, the more cars they will own/purchase in their lifetime.
3) The second car someone buys is more likely to be the brand of the first (used) car than any other brand.
Ford said support used cars and car repair, and you expand the market, creating more buyers tomorrow. I hope that's the conclusion HP is working from.

Retroworks de Mexico and ARI West

Check out our new Arizona website! We are pushing forward, to do more and more and more, recycling ewaste in Tucson and Glendale and Phoenix and Tempe and Sierra Vista and Green Valley and Scottsdale and and and...

American Retroworks West

"Free Free Free" The cost of Free E-Waste Recycling Events

In the public management / MBA program (BU School of Management, Boston) I graduated from in 1990, we studied government subsidy programs. We had many courses on private sector / free market system development vs. government subsidies.

The argument against "government subsidies" was their reputation for mis-estimating the need, over delivering service, poor sustainability, and undermining gains already being achieved by the private sector. Government, it was pointed out, could almost wind up playing the role of "Standard Oil" in the beginning of the last century, but there was no "anti-trust" laws or Sherman Act to protect businesses from government.

All of this is old hat. My observation, however, is that OEM subsidy programs are actually playing the role of "government" today.

Yesterday I had a long phone call with a friend, one of our original 3 clients. He sounded unhappy, because some other municipalities had taken part in a "free collection event". Why hadn't I offered free collection events to his district?

Sounds like a normal request. Who can blame him for asking for his clients what my competitors were offering ... er, actually, my clients?

I tried to make the following points:

1) Vermont had achieved 85% access to e-waste recycling six days per week, much higher than that for fewer days per week, TVs as well as computers. Our diversion rates were in the top ten of all states, despite not having a large commercial business clientelle.

2) Repeated studies had shown that (like free ice cream or free coffee) that the majority of participants were already buyers, responding to a "deal". They are predominantly not people who refuse to use the regular system. Increasingly, however, they are learning that free events pop up now and then, and a segment now hoards ewaste until the next event comes up.

3) Most OEM subsidy programs have a "splash" budget, targeted to run for a certain amount of time, then the fall off. Like free food in Africa (which can destroy local farming economies), the OEM gets buzz but the local infrastructure gets the hangover. Cities will not allow "free" payment of parking meters on an "event" basis, because they know they pass a quarter to their residents, but have the headache of enforcement and complaints afterwards. Under the Sherman Act, big corporations have to document that they are not running subsidies in a targeted fashion to subterfuge competitors... more below.

4) My own company's experience running free events, from Berkely to Austin to Western MA, is that the budgets are based on marketing/advertising. Once the story runs, the budget goes away. In the worst possible case, we held a very large free event, the sponsor reaped huge press, and then stiffed us nearly $25k. We offered to discount $15k of it, but rather than compromise, the client began telling all our clients we had not actually recycled the material (the disputed amount was not for running the event, it was the CRT processing cost!). The costs of the default get passed on down to our clients, a further burden on the regular system.

5) The OEM subsidy programs which are contracted out to national recycling companies are frequently used to damage competitors like me. They PREFER to run their free event in cities with long-established, stable and sustainable recycling programs. Given the choice of Plattsburgh (with no heavy participation) or Chittenden County, they will hold the free event (fees charged to the OEM) wherever it will hurt Good Point Recycling the most... by definition, in cities with the most established programs. We tried as a compromise to collect the material directly from our towns and deliver it to the competitor facility for 1 penny (to cover our transport). No, the national firm will only deal directly with our clients, once our truck driver is represented, the offer is no longer there. They even refused our offer to provide trucks and staff at the events for free.

6) When the event is ongoing, they go for cheap profitable material. Goodwill Industries advertises heavily they take Computers for free, they will not touch a TV. We are going to have to respond by taking computers for free, and raise our costs of TV recycling from $10 to $20. I don't think that does residents a service.

7) When the OEM is legislated into the system (vs. the retail system in CA), they cut deals which novice recycling stewardship advocates miss the impact of. In MN, WA, OR, ME and other "Stewardship Legislation" states, reuse rates fall 90%. The OEMs get "obsolescence in hindsight" and pass the extra costs right back to the consumer. The stewardship people say we need to have "One model". But it cannot be CA, MA, or FL or TX. It has to be MN. When I write or speak about it, it seems like I'm the grinch who stole "free recycling".

It's a dog-eat-dog world in the environmental business, just like any other. We are treading water, knowing that the OEM budgets are usually run out of PR. We are carefully working with OEMs, like Sony, who are trying to support common sense shared-responsibility systems. But even if we survive the onslaught of "free events" targeted at our core markets (which will burn out), we have to deal with the scavenging of high value items (computers) by other "free" events. My point is that the entire argument, debate and noise is over a system that charges under $500,000 per year in fees. NO proposed national system has gotten our infrastructure and end-market results for this price.
It gets frustrating, and when I get frustrated, I get grouchy. That fits the Grinch image. We have to just keep our Vermont company in good spirits, take the hits from non-paying sponsors and ill-intended free events and cherry picking opportunists with a grain of salt and a sense of humor. To apply for this position, please send your resume to us at PO 1010 in Middlebury, VT.

Ewaste vs. EScrap vs. Used Electronics

The definitions on the web are getting crazy. People writing that "up to X% of e-waste is not repairable". Or, "up to X% of the e-waste is discarded".

Well, it HAS to be discarded or it is not "waste", by definition, and by law. We refer to "e-waste" as the material which didn't have a useful purpose, residue, toxics along for the ride. But the portion which is "recycled" is E-Scrap, not waste at all.

The portion which is reused and repaired is neither e-waste nor e-scrap. We refer to the electronics intended for their original use as "commodities".

CRT glass in a landfill or thrown in a garbage heap is "e-waste".

CRT glass which is crushed up for recycling (in place of virgin lead silica) is "e-scrap" (itself a commodity).

CRTs reused, refurbished, fixed, resold, etc. are a pure commodity.

The same "noise" occured in past decades over used auto batteries. When it no longer works for me as an auto battery, I can discard it (in the woods or in a landfill, etc.) and it is waste.

When they are drained of acid (toxic along for the ride) they are practically pure lead. Lead is toxic, but it is lead, like lead from lead ore crushed up and processed at a lead-zinc smelter. We want that lead to be recycled, and we want whatever lead we buy (new batteries, bullets, hospital aprons, poison paint on toys) to be as much recycled content as possible. It is a logical fallacy to suggest that lead paint or lead gasoline is worse if it is recycled lead; the more lead must be mined, the more total lead is present in the environment. The fact that we don't want lead somewhere at all does not mean that we should not have recycled the lead.

If I am shot and killed, I hope it is with a bullet with the highest possible post-consumer recycled lead content.

There are groups which say that exporting the drained lead batteries back to the factories in SE Asia that make auto batteries is an environmental crime.

I would suggest that all people interviewed by the press on the subject be asked whether lead should be allowed to be exported to car battery manufacturers in Thailand. Any who say "no" may still be interviewed but listed as follows: "According to XX XX, a known idiot, ...."

Mining metals out of ocean reefs is sick and worse than any type of recycling, the worse, imaginable, if it is actually recycling. If the lead is thrown on the ground as waste, it's a double crime, because the recycled lead is not reused or recycled but wasted, and more lead must be mined to replace it.

Fair Trade Needs Support

We are going to get outspent by the Japanese "DOS" system ("Destroy On Site"), and the Anti-Gray Market alliance. We are hoping to set up a leveraged compromise, where refurbished product retained value is kept but "punted deep" into markets where it will develop future buyers without cannabalizing sales. This would involve a partnership with OEMs, the United Nations, and projects similar to Las Chicas Bravas in rural Mexico.

HP is investing in some kind of electronics recycling infrastructure in South Africa and India. I hope that "can't beat em, join em" approach works wicked better than the approach in 2002... with $6M you could finance, and control, a heck of a lot of capacity, creating sustainable jobs in the developing world.

It could result in the same savings to the US government that South Korea dropping out of USAID created, when the people there bootstrapped and reverse-engineered themselves into an OECD developed nation, home of Samsung, Hyundai, and others. I hope I will live to see a Cameroonian Mbumba-Kia or similar. I'm only 47, if it happens as quickly as it happened in Singapore, Taiwan, Korea and Guangdong, I have a really good chance.

WSJ Best Writer - John Fialka

John Fialka of the Wall Street Journal was usually spot on. He was the best environmental journalist I know of, and I hope he'll publish from time to time from retirement.

He wrote on the need to change the General Mining Act of 1872 in 2007, before a hint that the 137 year old law was overdue for an end to mining subsidies.

He broke the story on USA Mercury "recycling" in April 2006 (exporting what we recover from lamps to alleuvial gold miners in Congo and Amazon river basins).

John Fialka is to environmental science what Alanis Morrisette is to love songs.

John Fialko retired, and leaves a huge hole in the environmental movement.

Western Medecine is probably the best in the world, but the origins of health science were in alchemy... western medical practices went through some strange scatalogical obsessions early on (feeding mercury to King Edward to improve his bowel movements), but what saved it was dialectic, honest confrontation, competition and challenge.

Progress in environmental health faces the same scatalogical challenges - witness USA's obsession with recycling standards (under RCRA) as compared with virgin ore mining (under Superfund). John was a writer I always looked forward to reading, I knew he would improve me as an environmentalist. Fareed Zakaria and Tom Friedman are still out there, but they are usually generalists who haven't demonstrated Fialka's killer cross examination skills on the worst of environmentalism's well-intentioned practices or revealed adverse consequences in a game-changing fashion.

The fragmentation of journalism is well documented. Blogs and twitters disinintigrate expertise into shiny provocative slivers. I think it's a good thing overall, given how seldom a Fialka came along and lined up the cue balls and avoid sing-songing. But it's going to require that the current generation of environmentalists follow strict and vigorous scientific method and divorce the dogmatists who thrive in any church, including ours. Fialka was the closest thing environmentalists have to Michael Servetus... the dude in the Catholic Church who tried to leverage the Church's value and infrastructure to promote the study of health, but who was intellectually drawn to the reformists.

History Channel had a brilliant (and cheap) documentary on Michaelangelo (a closet reformist intrigued by reformists and alarmed by the Church's punishment of people who translated the Bible from Latin into accessible language). It should be required viewing in environmental studies courses in college, which are poisoned by self-referential, back patting attaboyists.

This is not about just being contrarian to annoy people. This is about the urgency of the threat of global population and extraction on the planet. We cannot afford to spend money on sugar pills, as Plato warned in The Republic would get voted on in a democracy against effective but bitter medecine offered by philosophers. But the stupidest thing is bitter placebos, like fluorescent lamp recycling, leadfree solder, and bans on exports of electronics for repair. Spending limited environmental dollars to do environmental harm. Faith in bitter medecine because it's bitter should be the low-hanging fruit. Challenging it is like challenging the Church in order to save it, a reference that only true fans of John Fialka would really understand.

E-Waste Recycling Legislation. Re-Boot!!

Ok, start over with a blank piece of paper. What are the needs for good ewaste or electronics recycling policy? We have had waste bans (putting fees on users at point of recycling), advance recycling fees (ARFs charge for recycling at point of purchase), and several varieties of "stewardship" (requiring manufacturers to pay, either as a percentage of what comes in to recycling centers, or as a percentage of what is sold out).

First define the needs:

1) Wide consumer access to recycling in a timely manner.

This is where complicated systems really fail, because they take so long to pass. States like Vermont, which have voluntary programs and do not even have a waste ban firmly declared, have higher recovery per capita during the past decade than states like Minnesota, which debated and tinkered for most of the decade. Minnesota apparently had a higher diversion per capita in 2008 (reportedly including 2007 tonnage, old CPU scrap, prepurchased 2009 tonnage). But even if research into the numbers turns out that it was the same material in pounds per capita, Vermont can't be expected to meet MN if it has been taking console TVs out of the waste stream since 2001, while Minnesotans left them in the basement.

For timely manner, KISS. But now that the Stewardship legislation has momentum behind it in some states, it may be the fastest way to kick start a state that hasn't started yet. Or "whatever will pass, do something NOW." States like VT and MA got farther simply because they got a head start. Some Stewardship advocates repeatedly state that one-time collections, like big free events and all material being collected in one year, demonstrate higher recovery rates. This is a mathematical and logical fallacy. If you stay away from the dentist for 8 years, and then have 3x more cavities filled in one year than anyone else, you are not the expert in dental policy.

2) Affordable

This will connect directly to #3, hierarchy. There is a limited amount of environmental dollars in the total economy. China demonstrated the ineffectiveness of creating one super-eco-city, spending all of its money on a super environmental place, rather than making modest improvements at all the other cities. If you spend all your money on waste disposal, you may come up short for carbon abatement or water quality. The degree to which the Free Market is fighting you, you really need to look at where the bad subsidy is and attack it, because just fighting fire with dollars may be destroying some efficiency you didn't consider. See below.

3) Hierarchy of reduce, reuse, recycle.

Waste bans, stewardship advocates argue, recycle but do not reduce. But the states held as models have all demonstrably hurt the hierarchy, almost without exception.


The Stewardship people mistakenly think that Manufacturers caused the obsolescence, and that takeback models will result in reduction. The manufacturers do cause waste - by insisting in every state above that reuse programs be ineligible or illegal. These states all saw reuse of computer equipment fall exponentially when their bills passed!

The manufacturers are not evil but they have a conflict of interest in the management of used equipment, especially PCs and cartridges, when white box manufacturing has had the highest rate market share growth than any other brand including Acer and Lenovo... which were themselves white box manufacturers ten years ago that grew into brands.

Crushing up useful and refurbishable equipment costs the system money. In a state like Vermont, my company has to satisfy client by client, town by town, city by city. If we miscalculate and don't service a client, we lose them. But in a stewardship state, a small number of manufacturers (some of whom actually band together - see MRM) choose which recycler or community they will buy their "share" of tonnage from. And they tend not to like companies that emphasize reuse.

4) What about reduction?

Well, first most manufacturers didn't manufacture the CRT or display devices. Those were contracted out, just as recycling is. The theory that they will design materials differently works with placebo legislation... they arent' going to change the manufacturing because of Vermont, let Europe do that.

What did cause the obsolescence that is supposed to be fixed?

- Mining subsidies keep copper, aluminum, gold, palladium, etc. cheap to make new electronics from (and make recycling more expensive in comparison).
- Microsoft. Vista killed the P3, XP killed the P2. MS controls the utilization of chips from Moore's law. And arguably, software OS would be a simpler thing to attach stewardship fees to.
- FCC. When they stopped analog TV broadcasts, THAT is what made the TVs obsolete, NOT lack of foresight by Sony, Sharp, Toshiba and Panasonic.


The right legislation will be a holistic environmental policy which will share recycling costs between consumers, government, and manufacturers. When they all split the costs, they tend to agree more on the best use of funds. And I would add mining and raw material companies, I don't know why BHP Billiton and Xstrata are not in the discussion (multi-billion dollar mining conglomerates which do not share royalties or legacy Superfund liabilities with government).

The correct legislation would create a Fund for state contracts, similar to the ARF in CA or the Clean Environment Fund for bottle deposits in MA. The fund would be contributed to by manufacturers per market share, but also by mining royalties, software operating system royalties, export container taxes, analog bandwidth auctions.

The states would bid out contracts, like CA and MA do, but those contracts wouldn't divide up transportation and collector and processor money. Put the value on the processing, and the processors will compete for transportation. If you allow processors to reuse and practice Fair Trade Recycling exports, the cost of the processing will go down, and the Fund can get raided someday to fix health care or something. That's always thrown at me as a reason AGAINST having a contract fund, but the alternative is that the "recycling" fund gets spent on stupider and stupider and expensiver and expensiver slices of the waste stream.

CRT Glass End Market Audits: Yuma continued

I spent a long time with VP of Dlubak today, going over our planned trial of CRT glass fines we would take back to the smelter in Mexico. I also apologized for the delay in shipping our bare CRTs there, but I knew they were in no hurry for our small quantities.

The EPA enforcement paperwork was a terrific tool for us to use and translate into Spanish - had it not come out, we might have made some of the same mistakes with gaylord labelling, and commingling glass types (since the smelter doesn't care, it would be easy for us not to care. For that matter, Dlubak prepares mixes of glass according to smelter purchase orders).

The main thing people need to understand is that beating up on Dlubak over a minor fine is a case of "the perfect being the enemy of the good." An Arizona blogger announced Dlubak was shipping the glass to the Philippines (Nope.), Jim Puckett is quoted as saying there is a lot of cadmium in the glass (some very rare 1960s color TV tubes used cadmium to make yellows, and BAN.org was citing a US Navy CRT built in the 1950s as their information source on cadmium). I was alarmed to see California companies pushing Dlubak under the bus, implying they are shocked to see lead silica in a pile.

The fact is that the CRT Glass Test is the single best indicator of whether an electronics company is shipping toxic waste overseas. The bad CRTs that cannot be reused or repaired are the biggest cost to an electronics recycler, and the companies like Dlubak and Videocon and CRT Processors, which are tackling that expensive material, need to be protected and thanked. They are not in the business of covering up for exporters who avoid the cost of CRT glass washing and processing, they are the ones who can tell you if a company (like mine) really is paying them $150k per year to manage the bad CRTs (we do).

BAN and my company (before WR3A.org was formed) released a joint paper employing the CRT Glass Test, and it has been embraced by EPA, by California CRRA, and others as providing an easy way to certify your electronics recycler is really recycling. We cannot do this without companies like Dlubak.

So keep abreast of how Dlubak reforms and corrects the mistakes identified in the EPA enforcement. But don't throw them under the bus. As I told Popular Mechanics in my most famous geeky interview last year, the CRT glass processors are the hardest working companies in the e-scrap business. They are NOT managing "e-waste". eWaste is what happens if you throw it away and it DOESN'T get recycled. These are the good guys.

BAN could have pointed out that their own 2004 Study (done with me) demonstrated the critical importance Dlubak plays in the recycling chain. Instead, they added to the hysteria in interviews about the pile. Mining produces piles of lead and silica 100 times the size of Yuma's, and leave a scarred mountainside 1000 times larger. Recycling is good.

Ban Crt Glass Test 2004

Memories of what you did

For some people, I guess, reflecting back on your life means remembering your memories. If you have good memories, you enjoy them. Hedonistically, I guess. You are, right now, enjoying the memory of what you did then. I guess serial rapists and criminals returning to the scene of the crime subscribe to this. People who read this may find that sad, but saying it is probably true of other people isn't the same as being cynical.

For other people, memory is kind of junk mail thing. I mean, if you don't open your mail for 15 years, you can pretty safely throw it into the recycling bin with the other "direct mail" recycling. So recalling your memories of 15 years ago isn't any more useful than opening mail of that decade. People who read this may find that sad, but saying it is probably true of other people isn't the same as being cynical.

Me, I operate based on my actions being real, frozen in time. This is very similar to those who say God is seeing everything we do, and I have more in common, morally, with those "God-fearing" people.

But the reality of my past actions is something different to explain to my children than all-seeing, all-knowing, third party judges.

I thought of this while watching clouds overhead tonight in Middlebury. I saw the clouds (not rainy, but cumulous, nearly-rainy). And the farther away they were towards the horizon, the different they looked. But you could see that someone standing 20 miles away, looking up, would see a similar sight to that I saw looking up in Middlebury.

If that person was 2 years ago, looking up might be to them what remembering, or looking at the clouds from afar, is today.

This probably belongs on my other blog. But I believe that the things I do are forever, they may recede in perspective, but a dinosaur whose fossil is never found is as real as a dinosaur plaster skeleton in Chicago O'Hare. It is the only meaningful way to live, as every action you take now never disappears, it is as real as a stone that may or may not become a diamond.

"He goes down to the park and warms his feet."

CRT Glass and Stewardship

"All my life's a circle. Sunrise and sundown. Moon rolls through the nightime, til the daybreak comes around. All my life's a circle, I can't tell you why. Seasons spinning 'round again, years keep rolling by." - Harry Chapin

To paraphrase, "All my life's a cycle". Here is news about BAN's complaint about a big pile of CRT Glass in Yuma, AZ. CBS local news keeps covering it as an outrage.

The pile is in Arizona, a mining state, and was originally allowed just as mined lead and mined silica would be allowed, under the General Mining Act of 1872. Admittedly a terrible standard, but the AZ DEQ applied the same standard to recycling (secondary material) and mining (primary lead).

The company, Dlubak Glass, is one of a handful which allowed USA companies to pass the "CRT Glass Test", which we created, and which was endorsed by BAN in 2004. Basically, it says if you are skipping the most expensive recycling process - domestic labor and insurance to process the bad CRT tubes - you are likely the source of the junk CRTs sent overseas.

Our company opened a Mexican maquila operation to demanufacture TVs, coverage below (Las Chicas Bravas). My biggest concern before opening the plant was that the CRT glass not accumulate and be unaccounted for. We do NOT want a letter like this enforcement documentation on Dlubak, as filed by the AZ DEQ.

We have a smelter in Mexico taking the glass, but also were encouraged when Samsung began taking the CRT glass for glass-to-glass recycling. Meanwhile, we sent our own VT CRTs to Electronicycle, which was purchased by ERI of Fresno in 2007. ERI is a big Pledge Signer, E-Steward, etc., so we figured we are well covered under that banner.

ERI sent CRT glass to Samsung (the PO we originally opened) and to Dlubak. BAN decided Samsung cannot wash the glass in Malaysia, complained to the Malaysia EPA, and the Samsung import permit was cancelled. That left Dlubak and Mexico.

Now BAN is criticizing Dlubak, and implicitly, ERI, for accumulating the CRT glass.

They don't want it sent to Samsung to make CRTs out of. They don't want shippable quantities prepared as mined silica in AZ. Now our Mexico smelter is getting nervous, will they be the next company attacked? We may lose our purchase order, which we were going to fill... as a test sample... from Yuma.

Now what? This is going to make CRT recycling even more expensive for municipal governments, which will cause legislation to pass mandating manufacturers take the cost, and pass it back to consumers. As part of the bargain, the manufacturers will incorporate anti-reuse (anti-gray market) provisions and erect protectionist sales rules to keep new TV and PC manufacturers out. The cost will be passed to the American consumer. And the recycling costs will make mining more attractive. Remember mining? The source of lead piles all over the west, which bankrupted Superfund?

Meanwhile, this drives the e-waste export business underground, like the war on drugs. I feel like a parent environmentalist surrounded by too many children environmentalists running around with sharp objects.

Listen, they are signing a song of their own...

"The Perfect is the Enemy of the Good!"
"The Perfect is the Enemy of the Good!"
"The Perfect is the Enemy of the Good!"

(sung to the universal tune, "nyah, nyah, nyah-nyah, nyah"

PBS - Retroworks de Mexico and Vermont

Wow, our Vermont and Mexico ewaste (एवास्ते) recycling has so much traction. It is very difficult to get ANYTHING started, or financed, in this economy. But the moral support we are getting is incredible. Here is the latest, none other than PBS, coverage of fair trade and responsible e-waste practices.

(बी रेकुएस्ट, रेपोस्तेद)

Womens' rights in Mexico, jobs in Vermont, responsible recycling. Sometimes I think I care about this project and business too much. Entrepreneurism is both a hobby and a lifestyle, so everything you make goes right back into it.

लेगल, एथिकल, Fair Trade of ewaste is a moral imperative। -वास्ते रेच्य्क्लिंग