Thanks for the tip to the link below goes to Attorney John Bullock, who also attends the Basel Convention meetings.
I have given two responses to BAN so far about their representation that, while Annex IX of the Basel Convention explicitly says "YES" to export of CRT devices for repair and refurbishment, and even has a footnote saying that some Parties consider items received for reuse and repair to be commodities and not waste, that (in BAN written responses to my company's offer to sign the Pledge), the export for repair and reuse is not "really" allowed.
My first response was "what does a ruling on mobile phones have to do with CRTs?"
My second response (yesterday) was, "how did a ruling expected to take place in February 2010 (on mobile phones) discount the written allowance in the text of the convention four years ago?"
Thanks to John, here is a copy of the Mobile Phone Partnership Initiative 2.1 Chairman's paper, BAN comments, and other comments. I can now catch up with the discussions on cell phones since 2006, which I admitted I had not read.
Guess what? Our factory takeback program (the former monitor manufacturer which now buys back 6 year old monitors for re-manufacturing) is apparently completely compliant, because the parts removed are NOT disposed of in the non-OECD country, they are recycled in an audited end-market chain of custody!
In fact, the entire WR3A approach, which is to legalize, streamline, audit and monitor the repair market is apparently exactly the approach of the MPPI document!
I need to review it further but I will be posting excerpts in the days to come. But it appears to me that the same factory which has a legal permit, which properly recycles incidental breakage and fallout, obtained ISO14001 and ISO9000, gives detailed reports on each and every shipment, is following precisely the recommended approach by the Basel Convention. It appears to me that BAN should be giving my company an award.
No comments:
Post a Comment