Memorial Day: Fear and Greed, Part 3

There is a cynical expression in Africa, used in response to "fears of the rich".   Why worry about toxics which may kill me seven years from now, when there are so many things that may kill me today?

Just as there are Useless Lists of Jobs Beneath Wealthy People, there are fears and phobias that the emerging markets don't have on their list of priorities.  That can be an opportunity for exploitation.  Yesterday's post described how EPA's Environmental Justice team came on board to make sure that "a clean local environment" was a right for every American citizen.

I learned today about careers in actuarial science (CNN).  It's about the statistics of risk and benefit, which (those who know me, know) I attribute to most of my life success.  (Taking credit for good luck, others call it).  Wikipedia 2012.05.28
An actuary is a business professional who deals with the financial impact of risk and uncertainty. Actuaries provide expert assessments of financial security systems, with a focus on their complexity, their mathematics, and their mechanisms (Trowbridge 1989, p. 7).
Actuaries mathematically evaluate the likelihood of events and quantify the contingent outcomes in order to minimize losses, both emotional and financial, associated with uncertain undesirable events. Since many events, such as death, cannot be avoided, it is helpful to take measures to minimize their financial impact when they occur.
According to the article, actuaries are one of the most sought-after degree holders, with virtually 0% unemployment.   What I'm curious about is what a professional actuary would say about "recycling" and "reuse" endeavors, with their associated benefits and risks, in a developing nation?  

One of the saddest stories I remember from Peace Corps in Africa was a young woman who spent a year teaching farmers to cultivate fish ponds.  Her favorite and most apt farmer/student lost his 1 year old son, who drowned in the fish pond she helped to dig, and she quit the service and returned to California.  Perhaps an actuary would say that the protein in the diet is worth the risk, if you learn from the lost life and make the fish ponds a little safer.  (Yes, this is similar to the story of the boy I helped bury who drowned in his father's well.  Not digging wells is not an option.  I taught by twins to swim by the time they were two years old).

Unlike the Peace Corps volunteers, the villagers really don't have much of an option to move to San Francisco.  If they try illegal emigration, that has its own risks.  My best friend from Africa married my Peace Corps replacement and they moved to the USA.  He was a muslim who fell into drinking in the USA, lost his family, and has been in and out of prison.

Finding a scapegoat for the things that killed us today is rarely useful.  The amount of fear that we can realistically project onto something that may kill us seven years from now is also practically useless, unless we find a scapegoat to leverage... the answer to that "unless" depends on the wealth of the scapegoat.  The environmental justice and Stewardship philosophies may not be built upon this attraction to leveraged wealth... but they cannot help but be influenced by it.

We can blame ourselves, or government, for the fish ponds.   We can blame corporations for the stewardship of the toxics.  But like actuaries on a battlefield, the entrepreneurs I've met in slums and emerging markets don't wait around for someone to blame.  They find the most value they can, the smartest way that they can.  It's not waiting for a big multinational corporation to pay for a modern shredder.   It's not taking back an exhausted 1980s TV from Lagos for repair.  The best thing they can do is get a laptop which needs the fan cleaned, or a computer with a dead capacitor, and repair it, earning a months wages in forty five minutes.  It may be safer for the white volunteer's shiny conscience to escape that, or say they shouldn't have had to make that choice.   I didn't leave, and don't intend to.

When a risk is a consequence of trade, and the trade is a good or service between someone wealthy and someone poor, it might be about exploitation and it might be about race.   But sometimes a cigar is just a cigar.  The actuarial science of life for the developing world says that Foxconn and contract management and low wages are a better path out of the poorest ditch than the promises of Mao or Al Qaeda.  Having a boss sucks.  But having a fair boss, or a good trading partner, doesn't suck nearly as much.

Memorial Day: Fear and Greed, Part 2

EPA tried to simplify things a few decades ago with a "Solid Waste Hierarchy".  The first was "recycle, then incinerate, then landfill".   That drew an environmentalist backlash, and the "new hierarchy" in 1990 Earth Day was "Reduce, Reuse, Recycle".  Neither hierarchy anticipated the international trade issues and controversies.

Reuse and repair beats recycling.  Ghettos and barrios are the best places for that work... Just as auto and engine repair is no longer done in Manhattan.  But that collides with a social fairness "tab" we have open, and in the late 1990s "Environmental Justice" became EPA's forray into social issues.

Definitions from wikipedia 2012.05.27
The United States Environmental Protection Agency defines EJ as follows:
Environmental Justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. EPA has this goal for all communities and persons across this Nation [sic]. It will be achieved when everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision-making process to have a healthy environment in which to live, learn, and work.[5]
In other words, this environmental outcome concerned the human perception of environmental risk... people who were poor had the same vote on EPA attention as the rich people.  A clean and safe environment was seen as a human right, a protection of people.

The attention of government regulatory staff was to be divided equally, to protect us all.  This shifted the radius or loci of EPA from protecting high property values to protecting humans equally.

In this paradigm, the value of protecting the environment is utilitarian.  How many people are in contact with the environment being protected?

This is not a song for the woods, or rain forests.  It's only the giving that makes you what you are.

Memorial Day: Fear and Greed Part 1

The more I try to crystallize the issue in this blog, the more it is about trade and exchange between rich and poor.  The exchange is a value, and the fear of exploitation is a value.  Some make their value in the margins of exchanges they make, others make their money through their authority over those transactions.

Whether we draw two big circles on a map and call them "OECD and non-OECD", or seven circles for continents, or 193 nations, or circles which show cities and peasants in those countries, or draw lines within a city between the high property values and the ghettos, it's ultimately about the transfer of wealth and value.   When a rich man employs a poor man, or a poor man buys something from a rich person, or a daughter marries across an economic line, opinions and suspicions sharpen.

Is trade between wealthy and poor exploitation, or opportunity?  Who is the authority or referee?

Jim Puckett says in his interviews in CBS 60 Minutes and Frontline that the deck is stacked against the poor in any exchange.  The economic have-nots will be abused and worse off due to the trade of second hand goods.  This line of thinking has some friendly listeners in the "environmental justice" arena, and the anti-globalization movement of Seattle.

I was a critic of how the USA's most toxic industry - hard rock non-ferrous mining - moved to rain forests where no one complains about the cyanide, mercury, and other toxic runoff.  Those concerns brought me into the recycling field, in fact.  And here I am in a battle of wits with a fellow environmentalist over how our raw material policy should play out worldwide.

My concerns about hard rock mining, however, were never pinned on a false hope of economic segregation.  Boycotting and segregating people we are uncomfortable or uncertain about has led to many "trail of tears", and many burned bridges.  Doing the right thing means doing something, but it isn't to throw a garbage can through the collective window of the recycling industry.  Fair trade makes more sense, and is not something Basel Action Network should try to make people afraid of.

Tech, Toxics, and Ju-Ju:  Leverage fear, create authority
In his editorial response to my first widely published column, "We Shouldn't Have to Make that Choice" (reprinted in E-Scrap in 2009), Jim Puckett said that he didn't think Fair Trade meant "poisoning people".   Toxics is a scare word.  Jim was clearly trying to make people afraid of the economic exchange.   He tells people that replacing or upgrading a part is hazardous, toxic, polluting.  He knows he's wrong, he just doesn't recognize why he's doing it. It is not, as he claimed, about a "loophole" of reuse.  If it's resolved, his authority diminishes, and he's not ready to retire.

Create concern, especially visceral concern (photos of children).  Promote yourself as an authority to reduce this concern. Sell certification.   Profit!

You do not create "environmental justice" by creating a vacuum or boycott of trade.  Justice is, by definition, a judgement call, a negotiation, and a settlement.   You do not stop exploitation by labeling people and segregating them.  


Did Facebook public offering hype set it up for a perceived fall?    SSFF?
(note:  This summer I intend to weed out and take off line the weakest blog posts going back to 2005... the ones that SSFF.)
SSFF is my inside baseball reference to a big announcement gone bust.  SSFF comes from a joke my parents found absolutely hysterical back in the 1970s. The only other source I found for the SSFF joke, online, was the transcript of a performance in North Carolina by a negro singer, born in 1908, who was telling the joke in 1981.

File:Tony McCoy fall.jpg
See wikipedia for attribution of Tony McCoy's fall
Two penny-pinching hillbilly brothers are looking at a bad year.  They were going to be eatin their seed corn.  They decide to pool their resources and use their trump card - inside knowledge on the fastest running horse in Kentucky.

They decided to pool what money they had and bet it on the local horse.  They were so excited that they got into a bit of a quarrel over who would go to the Derby and place the bet.   They couldn't afford to both make the journey, it would eat up the bet and reduce their winnings.  They flipped a coin and made a plan.

The winner would do whatever it took to go to the Derby as cheaply as possible.  He was to beg for food, hitchhike and walk, to save every dime they had to bet on this horse.

SSFF: "NY e-Waste Law is a Disaster?"

Live Presentation by NYDEC
I'm 'live blogging' during a presentation by Mark M. of NYDEC here at the NY SW Federation conference (Sagamore).   Slide one:   NY legislation allows OEMs to claim tonnage from businesses with fewer than 50 employees, colleges, and schools.

Missing slide:  NYDEC does not release the numbers for obligations for the OEMs (as of May), and tells them there is no penalty for not meeting tonnage the first year.  If the manufacturer doesn't know how many tons they are obligated to collect, well, they will pay for the CHEAP tons (computers not curbside TVs).  Our expensive TV recycling is without a "sponsor".

Missing slide:  Outcome - My company drops its largest municipal contract.  After not getting paid for months, we can't expect the OEMs to pay us if they don't have their obligations released.  We should have dropped the TV tonnage months ago and concentrated only on business and college institutional tonnage.

Missing slide:  We were suckers to collect curbside TVs for as long as we did.

Bitter?  Moi?  I'm just reporting on the sour grape harvest from here on the front lines.  I'm sure they have plenty of reasons to call this NY Product stewardship law a success.   But there are signs that they don't know what they are doing, and are making it up as they go along.

Strippers: Drinking Coca Cola With a Blindfold On

Selling Scrap Wire to Chinese (wire) Strippers?

Sometimes there is a really terrific end market which is all blue sky and sunshine.   A true model of fair trade recycling.  But it's impossible to match your supply exactly with the demand... you may have too much of something, and need a backup market.   Or you have too little of something, and cannot ban the buyer from trading with other people whose quality you don't control.
Recycling in a back alley

No one can ever have enough non-ferrous metal to dictate the copper market in China.

No one can keep their scrap copper from ending up in China.  Even if you sell it in the USA, its a sale or two away from Ningbo.

So, if you have clean copper wire, from yokes or degaussing coils (which shows you are demanufacturing TVs and CRT monitors, like a good guy), you are going to have to sell it directly or indirectly into a market that you cannot dictate the terms of.

Even if you visit your copper yoke buyer in Foshan, he may trade your load sideways at the port.  It's a commodity, things get bought and sold, and you don't know into whose hands your scrap non-ferrous will land.

If you sell to China directly, you are taking a risk that even your focus-material-free load is going to wind up unloaded at the same yard, surrounded by junk TVs (which probably were collected from Chinese households), and circuit boards and other focus materials.

If the yard buys from you and ALSO buys from your nasty bad USA competitor, the one you suspect deals in "toxics along for the ride", your sea containers are going to the same address.  If the buyer is then accused of being a nasty, brutish, and primitive wire burning operation, your defense is that you sold "clean commodities".
"Honey.." you say with your one phone call from the Chicago jailhouse.
"I was caught up in a raid of a gambling joint and strip house.  The police arrested EVERYBODY.  But I swear, I swear, I swear to you... I was drinking soda pop.  And playing solitaire.  And I wasn't anywhere even CLOSE to the strippers..."
You were in the wrong place at the wrong time.  Or you sold copper to the wrong place at the wrong time.

Your copper buyer was (gasp) a broker.  Only a couple of people have enough clean copper to sell directly to a smelter, and even then it may sit in a yard and be resold.   "Brokers" and "traders" are not bad words, some of us are just more honest about the fact that ALL the scrap wire is sold to them if we don't strip the wire ourselves.

Found Background (while cleaning my office)

I, too, was a poster child.

Found this "Mass DEP Retirement" poster today, while cleaning my office.  From the Apple Macintosh SE in the background, the photo would have been my first year at DEP, or just before I got the job there.  I think I was still at Earthworm Recycling, but moving to DEP at One Winter Street soon after.

While waiting for my hiring package to go through (a process which took months, and which I personally made an effort to shorten by running my own paperwork for new hires), I was writing a novel.  A short time after my retirement party here, my apartment in East Boston was broken into and someone stole the Macintosh.

It was like having a file cabinet stolen.  The computer was worthless, it was obsolete at that point, as far as resale value.  But I was unable to find the novel in the floppy disk drives, and had since moved to Microsoft.

Started the novel again recently, about 15 years later, from memory.

I got too busy to finish the novel when DEP work got going.   Later, a few months after the party here

This, by the way, is the same desk today.   I originally scavenged that wooden desk out of a dumpster at the JFK Building in Boston - where EPA offices were.  I vividly remember tying up the loading dock while I positioned the paper recycling truck I was driving to where I could leverage the wooden desk out of the dumpster.  I finished my masters using this desk, and then it was my home office desk until about 2002.

Now it is a monitor demanufacturing table.

I wonder how many novels we destroy.  It's the same desk, swear.  EPA - Robin - deman.  If you are retiring from EPA, take a look, it may be yours.  No one ever, ever worked as hard on it as it is worked on today...

100 Years Ago, before USA was OECD

[]Emailed from my mother in the Ozarks.  Great grandfather Freeland bought her property in 1908, then bought a used printing press and started a newspaper (Taney County Republican).

At the times William Freeland wrote his daily news columns, here is what the USA was like.  Today, more people have electricity in the non-OECD than in the USA during my parents childhood.

Here are some statistics for the Year 1910:
************ ********* ************
The average life expectancy for men was 47 years.
Fuel for a car was sold in drug stores only.
Only 14 percent of the homes had a bathtub.
Only 8 percent of the homes had a telephone.
There were only 8,000 cars and only 144 miles of paved roads.
The maximum speed limit in most cities was 10 mph.
The tallest structure in the world was the Eiffel Tower 
The average US wage in 1910 was 22 cents per hour.
The average US worker made between $200 and $400 per year.
A competent accountant could expect to earn $2000 per year, a dentist $2,500 per year, a veterinarian
between $1,500 and $4,000 per year, and a mechanical engineer about $5,000 per year.
More than 95 percent of all births took place at HOME.

... more

Good Point Recycling is R2 Certified!

[ May 2012, Middlebury, Vermont ]

John, Colin, Pete and Rachael did what was necessary to get our company R2 Certified.  We received our Certificate this week, and it has been registered with R2 Solutions and ANAB.

Who gets the credit?  Not me, that's for sure.  I was travelling to Mexico and South America and Vegas and DC during the past quarter, and sending staff to Nairobi, and negotiating Fair Trade Recycling contracts in Europe and Asia.  While I was off making it more difficult to certify and mass-balance more and more activity, the staff at Good Point Recycling was busy making sure the factory runs, orders are met, material is safely processed, and we do things right.  John and Colin did everything right, and Rachael and Pete made sure the state contract and our clients didn't suffer or stray from the rules John and Colin set.

Me, I just made the job harder.  It's easy to get certified if you refuse console televisions and just take off lease computers and laptops ("no hair on the meat", my pal Joe says).   It's easy if you aren't dealing with 12 countries, and 8 different purchase orders, with different reuse specifications.

Want to get R2 Certified the Easy Way?  Lay off the staff, stop the reuse and exports, don't handle residential material, and buy a shredding machine.  Better yet, don't do it in house - collect the material and send it to someone else's shredder.  The less your company tries to do, the less you must document.

It's easier to get Environmental Health and Safety (EHS) communication if you aren't cross-training women from Mexico, or running a job training program for challenged and disabled people with the local counseling service.  It's easier to certify a few things, than to be a "general practitioner".

Washington DC Testimony on E-Waste Rare Earths

I have to catch the 5A Bus to Dulles, and don't have many good pictures of the US Trade Commission hearings.  But I'll mention this:

The last panel of shredders and recyclers said that rare earth metals are not recoverable, and kind of waffled on the question whether hand disassembly provides better quality.

Here is an article by Bloomberg Reporter Adam Minter, who visited our Fair Trade Recycling partner in Malaysia.  They hand-disassemble hard drives there, and sell the rare earth magnets directly back to a company like Seagate in Singapore for direct reuse.  I'll show these magnets in a future post.

Here is an article recently posted by Fair Trade Recycling researcher Adelaide Rivereau, who is in Vermont from Marseilles, France, to study "e-waste" policy.  She has found definitive third party research showing that hand disassembly has greater value, creates more jobs, and has twice the environmental benefit when reuse components are recovered.

So how can someone testify under oath that rare earth magnets are not recoverable and hand disassembly is not preferable?

If you repeat the words "toxic e-waste", "toxic e-waste", "toxic e-waste" as many times as our shredder competitors said it, you can become entranced.  They made reference to an article from 2008 by National Geographic, talking about the dirty children burning waste computers from the city of Accra.

The photographer, Peter Selleck, ALSO visited the fair trade recycling company visited by Minter, and showed pictures of the reuse operation there.   But there were no children in those photos, so if I say "remember the really great operation in National Geographic?  That's the one where I learned to hand disassemble hard drives for magnets".   No one remembers the National Geographic in that context.

Toxic "ewaste" + Shredder = small pieces of toxic "ewaste" = $$$

USITC study on US exports: "Made In Polaroid"

I'm in Washington, DC.

Preparing testimony for the US International Trade Commission's study on used electronics exports.

I'm going to describe a remote, exotic, primitive place.

The "non-OECD".   83% of the population of the earth lives there.

All the hard drives and all the smart phones are made there, and (a little more shocking to some readers) more than 50% of the patents, design and engineering of those devices also originated there.   Hold onto your chairs - "Polaroid" LCD televisions (a significant share of the market) are not being made in Waltham, Massachusetts.

In fact, they are made in this same, exotic, faraway land of "non-OECD".   In the same kind of factory that makes - Sony!  Oh, you thought Sony was made in Japan?  That's SO 1995.

The Competition for Used TV Supply

In the Peru blogs, I described how used TVs from China were found in the markets where I used to sell used USA CRT televisions.

The people who used to buy USA used repairable / working TVs now buy Chinese repairable / working TVs.

Is the solution a ban on exports of used TVs from China to South America?  Or does that just mean that South America will have neither USA nor Chinese used (affordable) TVS?

First we ban USA "e-waste" exports, then we convince China to be afraid of brown children who receive ewaste...?

thanks to Adam Minter at  for the link to the photo above, from an article at Southern China Weekly. 

Scrap Metal Fraud: Diary of Export Heart Attack

Dear Diary,

This is a story of a scrap dealer, who has to make payroll while meeting Responsible Recycler standards in an international marketplace.  This is all true, all happening in the past two weeks.

China 2005
Monday... We are still dealing with the aftermath of a missed wire transfer from a USA client.   We took the wire (about $60K) for granted and wrote some big checks against it.   Someone at the sender's local bank claimed to be asleep at the switch (though I think it should be investigated whether the money was withdrawn from the client account on the day of the wire, and the bank was kiting it for 24 hours).   Bank fraud can mean the bank's fraud.  We were hit with about $1600 in bounced check fees and panicked phone calls with our own payees.  I took screen shots of our account showing the wire was late and the correspondence from the client sending us the money that their account had cleared it the day earlier.

Rachael, our CFO, makes the case that the wires are outrageous, taking $20-30 from the sender client and then $18 at our receiving bank... wonders whether we should use more paper checks to avoid the accumulated bank fees.

Tuesday:   To make up for the panic among our suppliers for the bounced checks the previous Friday (one of our loads was actually held and not unloaded until we sent another wire to cover the bad check, truck idling), we issue more checks to get the payables under 30 days.  To do that I need to sell some of the $150K in scrap metal that we have processed in the building.

Wednesday:  We re-double sort the green board to eliminate the "jelly bean" boards (yellow, purple, red, and blue boards typically made in China and typically having much less gold content), to get a better price than our last load sent to the R2 compliant buyer.   That takes extra staff time, and it's part of the reason we have so much metal value in inventory that I now desperately need to cash out.  The high grade printed circuit boards had been processed by our USA buyer for sale to Umicore or Boliden in Belgium or Dowa in Japan... it takes 90-120 days for our buyer to get the reconciliation on their load, worth hundreds of thousands of dollars.

They evidently got some loads back with way less gold than they expected and were told that the culprit was "jelly bean" boards.  They factored their loss over average loads going forward, and my company took a $6,000 hit.  They admitted they didn't know whose boards had how many jelly beans, it was an average spread out to cover their losses.

Does Spotify Turn Pandora into MySpace?

I have been an absolute lover and fan of Pandora Radio for years.  The music service is free, and you enter in an artist you like.   The artist may play, but as likely you will hear some other artist which people who liked the first artist are likely to also appreciate.  If you don't like a song, click thumbs down, and that gets factored into the future of your playlists on the station.

I love Neil Young, discover Greg Brown.  I find out that my dad's not just weird, that people who like Gordon Lightfoot also like Uncle John's Band by Grateful Dead (without liking other deadhead tunes quitesomuchthanks)... You can't choose what song to play next, but absent that choice it's like a radio station, background music.  I discovered some of my favorite songs during the past 5 years via Pandora.  Became a paid subscriber in January for my birthday present.

Now Spotify:  Similar to Pandora, but also like limewire or napster in it's display and order-by-artist-by-song selection, but legal and supported by ads.
(Note:  Recording Industry was a dumb idiot for not immediately embracing the technology and creating Columbia Record Club for big-value-teaser-downloads in the 1990s, the industry could have been Facebook now but chose to fight the last tape-recorder war over copyright.  ITunes finally kind of caught on but does kind of a lousy job in my opinion).
Love Spotify so far.  But would I have discovered MIA Paper Planes (a gem I discovered on Pandora) or Avalanches Frontier Psychiatrist (Boy Needs Therapy)?

(Note: savvy commenter already suggests

4 E-Waste Categories (Taiwanese Geeks Are Awesome)

Another Hypothesis:  There were basically Four Types of USA Computer Monitor / Electronics Recycling in the decade past:

  1. Honest companies with under 5% reuse.  They don't do the homework on the testing and reuse market, they shred everything ("good idiots")
  2. Companies that ship for refurb off-site, like mine, which achieve 25% reuse and are proud of it.  (honest and good)
  3. Companies that ship for refurb off-site, like mine, which achieve 25% reuse, and claim testing and everything is done in the USA ("good liars")
  4. Companies that ship enough good stuff that the export market forgives the crap, allowing them to ship 65% overseas... (bad exporters)

Inventor of Chinese character display from CRT
California was an example of Good Idiots.  There was little incentive to export good monitors to good companies when California taxpayers were shellling out 48 cents per pound to break them into pieces to put on the ground. 

There were companies I know of that were maximizing "TAR" or Toxics Along for the Ride.  They were willing to earn less for the good monitors in return for forcing along TVs and bad monitors.   I knew about them from the Taiwanese buyers Some of the worst exporters were - get this - Pledge of True Stewardship Signers!

The majority of e-waste recyclers in the past decade - About 50% of companies - were doing what I was doing (#2 and #3)...  The number who were transparent and proud began shrinking under BAN's scorched earth campaign vs. reuse.  And the buyers, who I visited and met with, were teaching me just about everything I know about display reuse and recycling.  I go to Africa as the "American expert" and talk about things I learned in China.

The Taiwanese were the earliest investors in Guangdong.  They have been enormously helpful in Mexico, South America, and Africa.  I keep running into Taipei Geeks all over the world, and they deserve a huge shout out.  Anyone who says "manufacturer takeback" and describes Taiwan as Guiyu is a certified laughingstock.

My Cousin Chevron's Taipei Hypothesis Grits

Chevron Agrees!!!!  With Chevron!
The Poster Child has so many uses.  Who needs a vetted "certification" or standard when you can take a picture of earth's most inexhaustible resource - brown kids under the age of 18?

We've seen the success of an "anti-ewaste" campaign which never had a number or statistic or even a proper interpretation of Basel Convention Annex III or Annex IX... they had something better, photos of children and the word "toxic" to describe something vaguely electronic and complicated which we all had in our basements and could feel guilty about.

Success breeds imitation.

Now Big Oil is into the act.   Take pictures of the kids, then make a demand for something you just so happen to already be doing (donating money to schools).   You co-opt the protest zeitgeist, steer it to your lightning rod, protecting your house.

The big difference between these two campaigns?

Probably the kid got some money from Chevron.  No kid ever got a dime from Basel Action Network.  They take jobs away but don't even write a thank you note.

And as long as we are making stuff up, here is a "hypothesis".  You know, that's an alternative to just stating something bogus as fact (like, 80% of the electronics exported are burned, or 80% of the e-waste collected is exported, or that Guiyu is "the most toxic place on earth", or that arsenic in Guiyu's river came from ewaste recycling rather than from the textile dyes, which are the source of arsenic in other rivers...).

Ahem, hypothesis, here goes...

"Jazz originated in New Orleans because poor families in close quarters encouraged music."

I've got a 15 year old on piano and an 11 year old on trumpet, right here, right now. Practicing.

" We Don't Export WEEE "

Of all the mantras a scrap recycler could have, this has got to be the WORST.

October 2011: "Call for Total Ban on Used Electronic Exports to Africa"

It means no matter what Africans do, no matter how good their recycling systems, they should be banned from export because they are AFRICAN.  They will always be African and can never properly import -E-Waste.

This is racist.

Psst.  Nick Mann...

Search the term "fair trade recycling", and search the term "boycott", and figure it out.

Or read the article.  There's a woman, Margare Bates, whom I've  never met but who seems to say exactly what needs to be said.

Trouble with Stewardship III

Regulatory Progress?  Or Regulatory Digression?

...And I'm here to help.
Were "E-Waste" Stewardship laws, as passed in over 20 states, an improvement over the Massachusetts Waste Ban approach?

The diversion rates don't say so. (Disclosure - the 1999 MA DEP regulation was my contribution - the first state with a CRT recycling law, always omitted from the list of states by NCER and other Stewardship advocates).  Did anyone actually follow to see whether the Massachusetts' treatment was bad for the patient?   Keep It Simple, Stewards?

If the movement for Product Stewardship is legit, and mature, it won't take these questions as an "attack".  It's important for technocrats to distinguish themselves from watchdogs.  They are not the same thing.

The new Stewardship laws are more complex, perhaps more sophisticated.   Regulators calculate what "shares" of electronics recycling responsibility to assign to different manufacturers.  They invent "diversion targets" that the manufacturers must either meet, or pay a penalty.

The Trouble with "E-Waste" Stewardship: Part II

Part II:   How States Rushed Into Surplus Technology Policy

We've all got our stories about the ten most feared words in the English language:  "I work for the government, and I'm here to help."  I spent the 90s as a regulator, with a bigger budget and more educated staff than I have today.   And I spent the last decade working in a newly regulated field, as a small business entrepreneur.

Despite company problems with state environmental regulators, most in my business agree that regulators are doing an important job.  If they weren't there, it would be cowboys and Indians.  I would be afraid to invest in doing something better, because another company might seize a share of the market by doing things worse (more cheaply).
  • If you don't take environmental justice and regulation seriously, I'm not the source for your policy.
  • If you take environmental regulation too seriously, I'm surely not the source of your policy. 
 "And that's ok."

Improving on an incomplete design:   If there is an existing set of regulations about squares, we can imagine a better and improved policy about squares.  Our "squares regulation" policy may evolve, differentiating between sides, producers of sides, areas, lengths, completion, fill color, right angles... Imagine an entire cradle to grave, complete lifecycle analysis, encompassing regulation of the "square industry".

Along comes a diamond shape.  Then a rectangle.  No problem.  The regulators derive a new policy based on the precedents set by the square policy.  They may just add a "check box" to the form.  The triangle... it's an interesting discussion, draft policies go back and forth.  But it's nothing the regulatory and policy community cannot handle.

Along comes a kitten.

You can see where this is going.

Working and surplus and repairable surplus electronics have a lot of "moving parts", end markets, lifecycles and ingredients.  But whether they are one man's trash or another man's treasure, the question is when or whether they have been "discarded".  What stewards are trying to do is make it easier to discard without making it harder to donate, sell, or use... and they got in the way of trade between Trash Man and Treasure Man.   This is ultimately about regulation of wealth and value.

EPA's 2007 CRT rule was meant to evolve the existing RCRA definitions for hazardous waste, while admitting that reuse didn't allow them to fit into the previous amendments to govern "universal waste".   The first RCRA solid waste rules had to differentiate for hazardous wastes, and the hazardous rules were too onerous for the product wastes that were generated universally.   The EPA UWR re-simplified hazardous waste so that companies could collect it from millions of small businesses and homeowners (though some states simply allowed "household" to mean non-commercial, and the lamps are dumped with MSW back at RCRA Square One.

The newest version of the CRT Rule tries to take the square, modified for rectangles, and give it a three dimensional shape - a shape to govern not the status of the good (discarded), or the toxicity (TCLP), but adapted for another dimension - time.   Since the reuse CRT might be discarded SOMEDAY by someone else who bought it, in the future, records on the sale needed to be kept, or a loophole could result.

The update to the CRT Rule takes it even another dimension, collecting the same record on the sale of the same device from the broker, the generator, the buyer, etc.  Three sets of records are better than the one set, which EPA never had time to read, ask for, monitor, etc.

The new rules involve not just records of different parties to the transction of goods which will one day (we suppose) be discarded.

Meanwhile, regulators have been using derivatives of the toxic waste risk to take "waste" into new dimensions.  Including the past, or the original cradle of the product.   CRT Rule follows the "future waste" to the country it retires to, and ROHS follows it back to the maternity ward.

What could go wrong?

ROHS (elimination of lead from solder) creates incentives for tin mining operations, once closed in the islands of Indonesia (for environmental reasons) to increase in value and reopen... we mine the coral islands of today to make tomorrow's waste less toxic.

And manufacturers in nations like China and India, where new CRTs are still made, make draconian rules about the used CRTs that will one day become waste, in order to protect brand new manufacturers making CRTs (which will one day become waste).  And the mining companies of lead keep the used CRT cullet from being reused.  Everyone gets into the act.

And Stewardship will solve all of this, we are told, by taking the regulations BACK in time, to the producer, the OEM.   They will set their long time agendas against planned obsolescence aside, and will work in partnership with regulators to protect consumers from ... oh, counterfeit and grey market product, perhaps.

Where is Haliburton?

Ah, yes.  The connection to yesterday's post, about the evolution of landfills to Subtitle C landfills, to incinerators, and flow control.

They are now making shredders to eliminate the labor from hand disassembly.  Those shredders don't sell well in nations which need hand disassembly jobs, or where reuse and repair techs are so talented that they shanzhai used goods into near-new, even counterfeit condition.

What they propose is to put those developing nations into a box.

They will simplify the way we look at the emerging market.

They will just ban the trade, and get us back to Square One.

Back when the perfect shape was the enemy of the good.   There's a Plato Cave somewhere for regulators to find the principles they need to make the policy work.

Which will bring me back to the conclusion of this three part post.


Keep It Simple, Stewards.

Don't start your policy around complex electronics made with coltan used for revolutionary internet cafes and surplus property added value planned obsolescence legal software emerging developing toxic market lifecycle jingo kitten problems.

Start with, say LAMPS.

The Trouble with "E-Waste" Stewardship: Part I

I'm not against Product Stewardship.  

keys to the city

The problem is, in their very first foray into command and control of "waste" and "markets", they chose something poorly defined and extremely complicated.  By applying a vocabulary change, and an invented word "e-Waste", they made surplus electronics policy and RCRA look a whole lot simpler than it is.

Looking back, I can see how we created some Myths about "E-Waste" [Top 10: Greenwala], and got ourselves into a world of ghost tonnage, capacitor recalls, conspicuous consumption,  planned obsolescence, local taxes, patent extension, non-tariff trade barriers, mineral policy, Egyptian revolutions and social engineering in the developing world.   So many things, it turns out, that running a successful paper recycling business, with a CDL from Boston, had qualified me, and others like me, to put ourselves in charge of.

One reason I went into electronics recycling was that it's rich and complicated field.  Compared to paper recycling (where I cut my teeth at a self-sustaining NGO Earthworm Inc. in Boston), computer recycling was dynamic.  Used PCs were extremely complex, with software issues (growth of software, not bad design, doomed the 486, Pentium I, etc.), repair and upgrade, counterfeiting, planned obsolescence, and international trade.  The analog signal auctions planned in 1996 to replace analog rabbit-ear TVs, the hard rock copper mining, the Superfund bankruptcy, mercury and toxics, and digital divide... It was like I'd moved from the farming communities of the Ozarks to live in a Recycling Policy Metropolis.

Having worked for 8 years in state government, I can tell you that state and county employees got excited by this too.   My years at DEP were a thrill and an honor, as I was able to recruit or hire some of the best and brightest staff in my lifetime.   We had a half a floor of environmentalists with policy and engineering degrees, many from prestigious schools in Boston.  And we had a track record - we had created curbside recycling, in the shoes of the officials who made bottle bill returns the law before us.  We had taken two laws, the bottle bill and RCRA, designed to promote solid waste, and had done things like create recycled paper content in federal purchases, saving trees and baby owls, and making it incredibly easy for our neighbors across the street to do so.  We made some mistakes (fodder for another blog), but on the balance, our market interference created certainty of recycling raw material supply, which had been the main problem for paper mills who were more confident about supply from a forest they owned than a fickly Earth Day hippie do-gooder marketplace.

So after a couple of decades of recycling successes, state recycling departments were flush.

We'd tackle "toxics next".  As I said to the staff in my last years at DEP (going strategically to take oversight of another department, perhaps), landfills weren't closing because they were too heavy.  The issue with unlined landfill closure was toxics.  We had to position ourselves to assess the quality of the waste we were diverting.

It was my own private mission creep, but as I grew my own department, others in the business of state government grew their agendas as well.

Tomorrow Part II:   How States Rushed In to Surplus Technology Policy