I have been contacted recently by people I trust and respect, who question whether it is sane or intelligent to "wave a red flag" at BAN.org or SVTC.org, the self-appointed custodians of e-waste ethics. Jim Puckett himself has most recently called me a "crusader", in kind of semi-non-derogatory way, though he also demanded that I take back a number of things that I cannot, e.g. that the Basel Convention Annex IX explicitly allows used electronics to be exported for repair and refurbishment.
The MPPI standard sets conditions, for cell phones, that the parts replaced or units found unrepairable must be re-imported for proper recycling. This, of course, is what WR3A established some years ago, as we set a standard for the 3 years of record keeping and documentation of actual reuse mandated by EPA in the "export for repair" language of the CRT rule. I've covered the philosophy of proper and fair trade between USA and overseas "refurbishers", some of whom are in actuality "Manufacturer Takeback" programs - the ORIGINAL CRT Monitor factory buying back the monitors it made originally for refurbishment and parts harvesting.
But right now I'm just thanking the people who have given me feedback. Some of it has been cautionary (are you crazy?). Some of it has been stoking my flames. A lot of it has been dialogue.
The purpose of the blog is twofold - to allow open air and sunlight into a vast overseas trade which has been stigmatized, and to properly disclose exactly what my company does and the standards we operate under.
There are plenty of awful export sites to be photographed, and plenty of USA exporters who are at best callous and indifferent to Toxics Along for the Ride. My business has benefited by BAN and SVTC exposing the cheating trade. But there are also important investments of millions of dollars - like in Tech Displays Mexicana and Samsung Corning in Klang, where the perfect has been made the enemy of the good. Recycling has only two enemies - mining and disposal. In either case, "the good is the enemy of the goo". In the "Big Secret Factories" which we trade with, there is a way for the 3B3K - the 3 billion people who make $3,000 per year, to get onto the internet, to tweet, and to expose dictators and create blood banks for maternity wards.
I guess I feel entitled, by having worked side by side with BAN in publishing the CRT Glass Test in 2004, to ask publicly why BAN is itself crusading for standards which affect only the companies which meet the CRT Glass Test, and affect none of the exporters who fail to document proper reuse and recycling.
My belief is that Jim and Sarah and Shiela and Barbara and Ted will understand that the dialogue respects their intelligence and offers them a way to find cracks in the foundation. It is not an easy belief to hold at times. But if they are going to claim that my company is discarding pieces and parts removed (as Jim claimed in a post to the google refurbishers group) rather than following the exact end-of-life trail which R2 and MPPI support, then I believe that withdrawing from the debate would hurt our ability to bridge whatever very small divide exists between the best practices and the perfect practices.
Testing and removing parts BEFORE and item is exported is the "perfect". It is definitely not what MPPI says. What our standards are is to remove groups which statistically show low likelihood of repairability, and to remove items which may in fact be working but are over-supply and unwanted or obsolete. For whatever percentage has to be recycled (remember, even warranty items fail), to properly reimburse the importer for the cost of proper recycling and to ensure that the proper recycling of failed warranty items is compliant with R.
The 20% or so of goods we export as "reuse" items are warrantied. We document exactly what is not repaired and document its recycling. We see an opportunity to move the factory from Asia to Mexico, which would remove the OECD debate over the failed parts and incidental breakage...
I am trying to attract investors, and Jim at BAN has said he regrets saying anything nice about me to one of the investors who spoke to him about our Mexico project. In that case, perhaps I have indeed stirred a hornets nest and shall regret it. But I think, on this Martin Luther King Day, that the regret I feel is the same regret that Rosa Parks felt some mornings on the long walk to work during the Birmingham Alabama bus boycott. In the rain, legs tired, as the year long bus boycott by African Americans continued. Recyclers must speak the truth, whether it benefits their investment, angers their bosses, or invites EPA inspections.
I hope it can be said about me and my company, that we are who we say we are and we do what we say we do. I am not going to smash up working equipment and tell people I am repairing them in the USA and meeting world demand. I am not going to throw the good, the bad, and the ugly together into a sea container and say that they are all exported for repair and reuse. I am not going to say that each item we fix is perfect, or that our end market is perfect. We will only document exactly what our standards are and document exactly what happens to the units at the end of their chain of trade. If BAN wants Vermont companies, like Small Dog Electronics, to insist that Green Mountain Coffee and Ben and Jerry's and Seventh Generation to boycott my company because our standards don't fit the definition of perfect, then my Vermont company will continue to lose business. If BAN tells an investor from Investors Circle not to invest in my company because BAN feels that it leverages my research into MPPI and Basel Convention Annex IX, so be it. I think that the people who have visited Las Chicas Bravas or the Big Secret Factories see that this is not an ego trip on my part, there is something good happening. And it is the same good thing that brought Taiwan and South Korea and Singapore out of hunger and poverty and made them the technnology giants they are today. Asians and Africans and South Americans are not *******s who are incapable of best practices. Indeed they have their own supply of ewaste and need investors to help them to drop their buckets where they are, and lift as they climb.
I may be stupid to stir a hornets nest, but I think that calling BAN and SVTC "hornets" is disrespectful. The sheer amount of money my company spends to properly recycle all the bad CRT glass, by itself, will distinguish us from the bad exporters exposed by 60 Minutes. The debate over the replacement of a faulty aluminum heat sink on the board of a used computer monitor sent to a Cairo repairman for sale to a blood bank demands to distinguish itself from the debate over unregulated export for disposal.