I was brushing up on my USA railroad accident statistics, preparing for a debate on which standard, BAN's E-Stewards or EPA and ISRI's "R2" practices, will be better going forward.
What I noticed this time was that the deaths, both from pedestrians and vehicle railroad crossings, appear to be steadily declining. From 4,021 deaths and injuries in 1981 to 1,221 ("preliminary statistics") for 2008.
The analogy has to do with comparing the "functional" and "tested working" definitions and standards in the Responsible Recycler (R2) certification versus the Basel Action Network's E-Steward certification. I think it is the major difference in the two standards, in terms of the cost of compliance (quarrels about "de minimus" are another). I have pointed out several times that the Basel Convention explicitly references export for repair and refurbishment, and does not say "tested working" anywhere in the document. BAN contends that it was "unfortunate choice of words" but that really what they meant by "repair and refurbishment" was that any part that might be replaced in the course of a repair or upgrade cannot be replaced overseas.
That is a standard that even "tested working" cannot meet. I would like to demonstrate that, statistically, the outcome of our shipments is superior to our competitors shipping all "working" product. The E-Stewards which are joining BAN's bandwagon have insignificant reuse rates, if any, other than Redemtech (which does not collect much residential electronics). But what we'd like to see is how the "working" product that is shipped measures up against our refurbishing factories.
Jim Puckett at BAN has said that although he appreciates our efforts to steadily measure and improve on the downstream management of incidental/accidental breakage through WR3A agreemenents, that even a single stick of RAM upgraded voluntarily (the buyer removes and replaces 128k Corsair RAM stick with 512k Kingston, and recycles the 128k RAM) constitutes a transboundary shipment of e-waste. I asked how they know that the buyers of "tested working" product are not upgrading? Do they replace USA 110v power supplies with 220 current power supplies? Do they replace 24X CDRom players with DVD players?
The risk of shipping to an expert refurbisher is that they will upgrade the product, producing a biproduct. The reward is thousands and thousands and thousands of affordable computers, which the average Iranian or Indian or Indonesian or Peruvian can aspire to use for access to the internet. BAN is suggesting that they can match the thousands of computers with either A) new computers (the "leapfrog" answer), or B) that E-Stewards will not just munch up the computers and monitors in a big crunching machine, but will actually hire Americans to fix the computers, swap the power supplies, and upgrade the RAM before it is shipped.
This came up in a discussion with BAN.org over what percentage of risk (fallout) would be an acceptable export-for-repair scenario. I wanted to know what we would have to prove to BAN when I made my annual offer to join the "Pledge". We had recently gotten our monitor fallout rates below 5%, and I quite honestly believed that it was a better outcome than my past shipments of "tested working". So I was challenging BAN to measure shipments of "tested working" product (how much of THAT winds up as non-working, accidental breakage or upgrade?) and found that not a single E-Steward actually measured the outcome of their "tested working" shipments at the other end! It's like claiming that BAN's railroads are safer because they don't measure or count the accidents! I suggested that even brand new computers sent under the "leapfrog" scenario would have some kind of fallout. Jim said those would all have to be returned.
I asked if they would be returned to the manufacturer, in China, and he said that was ok because it was legal under Basel for two non-OECD countries to trade. That means that a Chinese shipment of computers which is 85% working is better than a USA shipment of computers that is 95% working, because the 5% in the latter transaction is "illegal".
For recycling to work, we have to be realistic. We want to constantly improve. If another recycler has a better outcome than my company, a better risk (less fallout) and equal reward (number of reuse items), we want to see if we can do that affordably. If it is possible to do but no one can afford to do it, then you lose the reward.
From my many visits overseas, I have found the repairpeople and refurbishers are the best able to limit the 'toxics along for the ride' and are the best at reporting the actual useful versus lame product. Often the discussion is like this:
"Hey Americans, don't send us any more 15" monitors."
"The ones we are about to send are all tested working."
"Yeah, but we don't care about that. The 15" monitors are 28% Trinitron-"R4s" and we can't find the parts to upgrade those any more."
"What if we remove the R4s?"
"Ok, that would help, but we are getting all the 15" we need right now from Korea and Australia, and the shipping cost is lower."
"We already have 3,000 of them wrapped and ready, can we negotiate a price discount on those so we can transition out of them this month?"
"Ok, we are getting them for $1.44 at port now. Can you live with $1.50?"
These are grown-ups dealing with commodities. If the monitors were really being purchased for the copper, to burn the wires, hit the yokes off with a hammer, etc., why would the buyer pay $1.50, and why would they limit the monitors by raster or R4 screen shape?
What we are doing is the equivalent of the "Operation Lifesaver" program funded by the railroads. We admit the world is imperfect, but we honestly measure our contribution to the problem and we take steps to constantly improve. What BAN is selling is a myth, that the people earning $3000 per year, whose internet access is increasing 10 times the rate of the USA, are going to "leapfrog" us and get brand new computers. It is like accepting no railroad crossings, and offering the hope that product we buy in trains will "leapfrog" across the continent.
Everyone in America is buying monitors and computers manufactured in Asia. That is the only choice. On the east coast, they are being transported by rail car. I suppose that buying a computer shipped by rail, there is a chance I have contributed to the death of the pedestrian in the clip above.
What I noticed this time was that the deaths, both from pedestrians and vehicle railroad crossings, appear to be steadily declining. From 4,021 deaths and injuries in 1981 to 1,221 ("preliminary statistics") for 2008.
The analogy has to do with comparing the "functional" and "tested working" definitions and standards in the Responsible Recycler (R2) certification versus the Basel Action Network's E-Steward certification. I think it is the major difference in the two standards, in terms of the cost of compliance (quarrels about "de minimus" are another). I have pointed out several times that the Basel Convention explicitly references export for repair and refurbishment, and does not say "tested working" anywhere in the document. BAN contends that it was "unfortunate choice of words" but that really what they meant by "repair and refurbishment" was that any part that might be replaced in the course of a repair or upgrade cannot be replaced overseas.
That is a standard that even "tested working" cannot meet. I would like to demonstrate that, statistically, the outcome of our shipments is superior to our competitors shipping all "working" product. The E-Stewards which are joining BAN's bandwagon have insignificant reuse rates, if any, other than Redemtech (which does not collect much residential electronics). But what we'd like to see is how the "working" product that is shipped measures up against our refurbishing factories.
Jim Puckett at BAN has said that although he appreciates our efforts to steadily measure and improve on the downstream management of incidental/accidental breakage through WR3A agreemenents, that even a single stick of RAM upgraded voluntarily (the buyer removes and replaces 128k Corsair RAM stick with 512k Kingston, and recycles the 128k RAM) constitutes a transboundary shipment of e-waste. I asked how they know that the buyers of "tested working" product are not upgrading? Do they replace USA 110v power supplies with 220 current power supplies? Do they replace 24X CDRom players with DVD players?
The risk of shipping to an expert refurbisher is that they will upgrade the product, producing a biproduct. The reward is thousands and thousands and thousands of affordable computers, which the average Iranian or Indian or Indonesian or Peruvian can aspire to use for access to the internet. BAN is suggesting that they can match the thousands of computers with either A) new computers (the "leapfrog" answer), or B) that E-Stewards will not just munch up the computers and monitors in a big crunching machine, but will actually hire Americans to fix the computers, swap the power supplies, and upgrade the RAM before it is shipped.
This came up in a discussion with BAN.org over what percentage of risk (fallout) would be an acceptable export-for-repair scenario. I wanted to know what we would have to prove to BAN when I made my annual offer to join the "Pledge". We had recently gotten our monitor fallout rates below 5%, and I quite honestly believed that it was a better outcome than my past shipments of "tested working". So I was challenging BAN to measure shipments of "tested working" product (how much of THAT winds up as non-working, accidental breakage or upgrade?) and found that not a single E-Steward actually measured the outcome of their "tested working" shipments at the other end! It's like claiming that BAN's railroads are safer because they don't measure or count the accidents! I suggested that even brand new computers sent under the "leapfrog" scenario would have some kind of fallout. Jim said those would all have to be returned.
I asked if they would be returned to the manufacturer, in China, and he said that was ok because it was legal under Basel for two non-OECD countries to trade. That means that a Chinese shipment of computers which is 85% working is better than a USA shipment of computers that is 95% working, because the 5% in the latter transaction is "illegal".
For recycling to work, we have to be realistic. We want to constantly improve. If another recycler has a better outcome than my company, a better risk (less fallout) and equal reward (number of reuse items), we want to see if we can do that affordably. If it is possible to do but no one can afford to do it, then you lose the reward.
From my many visits overseas, I have found the repairpeople and refurbishers are the best able to limit the 'toxics along for the ride' and are the best at reporting the actual useful versus lame product. Often the discussion is like this:
"Hey Americans, don't send us any more 15" monitors."
"The ones we are about to send are all tested working."
"Yeah, but we don't care about that. The 15" monitors are 28% Trinitron-"R4s" and we can't find the parts to upgrade those any more."
"What if we remove the R4s?"
"Ok, that would help, but we are getting all the 15" we need right now from Korea and Australia, and the shipping cost is lower."
"We already have 3,000 of them wrapped and ready, can we negotiate a price discount on those so we can transition out of them this month?"
"Ok, we are getting them for $1.44 at port now. Can you live with $1.50?"
These are grown-ups dealing with commodities. If the monitors were really being purchased for the copper, to burn the wires, hit the yokes off with a hammer, etc., why would the buyer pay $1.50, and why would they limit the monitors by raster or R4 screen shape?
What we are doing is the equivalent of the "Operation Lifesaver" program funded by the railroads. We admit the world is imperfect, but we honestly measure our contribution to the problem and we take steps to constantly improve. What BAN is selling is a myth, that the people earning $3000 per year, whose internet access is increasing 10 times the rate of the USA, are going to "leapfrog" us and get brand new computers. It is like accepting no railroad crossings, and offering the hope that product we buy in trains will "leapfrog" across the continent.
Everyone in America is buying monitors and computers manufactured in Asia. That is the only choice. On the east coast, they are being transported by rail car. I suppose that buying a computer shipped by rail, there is a chance I have contributed to the death of the pedestrian in the clip above.
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