WR3A, BAN, NRDC, CRRA and other environmental organizations are now, in principle, "on board" for the proposal to allow SB20 Approved Recyclers to propose allowing Manufacturer Takeback (the contract manufacturing factories which buy back working CRT monitors). We will be setting a meeting sometime between 3PM and 5PM to take place at the "Prince of Wales" meeting room of the New Orleans Hilton on September 29. The cost of the meeting room has been generously donated by E-Scrap News; teleconference charges are donated by American Retroworks Inc.
The environmental organizations will formalize agreement on a definition of refurbishment which they believe to allow proper repair and refurbishment under the Basel Convention. While not every NGO agrees with every refurbishing practice, we have agreed that there are certainly SOME refurbishing practices which California could take advantage of, using the factories shown in this WR3A slide show. For example, if any monitor boards which might be replaced in an upgrade are removed prior to shipment, CRTs can be pulse-tested and exported to a CRT re-manufacturer, a compromise which appears compliant with either R2 or E-Steward Certifications.
Public awareness has grown that CA SB20 pays MORE to break the good units than these factories pay for working units, and that it has the following perverse consequences:
|From Contract CRT Manufacturers Album|
- The factories cannot get vacuum-ok CRTs from "good" companies so they buy lower quality CRTs from cheaters.
- Organizations like the UN are not able to get display units affordably (LCD prices still too high)
- SB20 factories need to wait too long for the approval of their CRT glass disposition
- California loses money.
DTSC has been one of the sources of confusion about Basel Convention and the requirement that CRT tubes must be "ruined" prior to export (through cancellation of the vacuum). DTSC has also raised other obstacles, which we have put to rest one-by-one:
- The revised cancellation language would require legislative authorization (FALSE - the legislation does not get into details and definitions of "vacuum")
- The export for refurbishment would be opposed by BAN and other NGOs (FALSE - NGO's agree that "prohibition" is not good policy, and good companies should fill the demand)
- The refurbished CRTs will be "double redeemed" for CA SB20 (FALSE - the factories overseas put the refurbished monitors into new boxes which, if ever resold in the USA, would go through retail outlets for ARF)
The WR3A's California Compromise meeting will introduce (via Skype) monitor refurbishing factory owners, UN officials, buyers in countries with demand for the refurbished CRTs, etc. We hope to have language which can unanimously be submitted for recommendation by all SB20 companies plus the NGOs. We will recommend an audit procedure to maintain very strict controls over what CRTs can be exported. Then we will deliver this to the Governor, the head of DTSC, and the Sacramento Bee.
The language in California relative to the "cancellation requirement" can be found here (thanks to Jeff Hunts at CalRecycles for his assistance and good natured response to the "monkeys running the environmental zoo" post).
14 CCR 18660.32 (http://www.calrecycle.ca.gov/Laws/Regulations/Title14/Chap08pt2/Article2pt4.htm). Those rules clearly lay out a method by which an approved recycler in the program may submit proposals for alternative cancellation methods. See 18660.32(d)…