It's four AM on Saturday in Middlebury, Vermont. I had a dream about "e-waste" recycling.
Usually, this blog pursues creative understanding, Imagining All the People, Recycling in Peace. It's like a parallel universe where John Lennon is the small business owner, and the Environmental Watchdogs are the Establishment, and commerce with entrepreneurs in Ethiopia, Ghana, Egypt, Angola or Cameroon is a form of protest... like interracial marriage in the 1960s USA heartland. The mandated labels of "universal waste" which Vermont ANR proposes to put on collected computers and scrap metal crimps this trade with red tape. Dudes, it's like the reuse stuff is getting drafted into a shredder, and it's like "manchester england, england"... (song from Hair)
But maybe this is simpler than I thought... A solution to the "universal waste" dilemma occured in my dream. (And there's a very funny video below in the 1960's Label Theme)
How can we be required by law to put a sign of "WASTE" on top of a device which also has a label which, by EPA and Vermont definitions 10 VSA 6602 cannot possibly be a WASTE?
It cannot be a hazardous waste or UW unless it is a waste (gasoline in your car is hazardous but is not a waste... it is still governed by OSHA, DOT, etc. but not by disposal laws unless you dispose of it.)
(13) "Waste" means a material that is discarded or is being accumulated, stored, or physically, chemically or biologically treated prior to being discarded or has served its original intended use and is normally discarded or is a manufacturing or mining by-product and is normally discarded.
Paperwork is good (and sign posting is good) if it accomplishes something.
Putting a "waste" label on an object which may be suitable for its original intended purpose (e.g. a diplay device still capable of displaying) is like labelling a wounded person "dead" in a hospital record book. It's paperwork which will have to be undone later if you are good at your job and can save the life of the product or patient. It's more red tape for the morgue than putting the toe tags on AFTER the patient ceases to be alive.
In many cases we get two items with something different broken (a laptop without a hard drive and a notebook with a broken screen), from two different places, and create a job for a technician to turn them into one working machine. Current drafts of VT regulations would label both machines "UWR", and the result would be a record that you collected 2 UWR pieces but only disposed of one, unless you continue to track the working one, which might be sold in a complex transaction. (In the January draft, the new laptop would still be waste if the battery held only 79% charge and you sold it on ebay for $400, so you'd technically need to do a downstream audit on the ebay buyer, who might be a young medical student who plugs their laptop into the wall regardless of the battery, as most people do).
Another source is the "Conditionally Exempt Generators Handbook", published by the Vermont DEC. Virtually every definition and label contains the words "spent" and "waste".
Plan C: we could declare ourselves a Farm. Vermont farms have specific protections from solid waste statutes. There is even language in Vermont Statutes specifically banning ANR from creating environmental rules for pesticides which are more strict than federal law. Ok. My ideas are getting worse as I continue.
Usually, this blog pursues creative understanding, Imagining All the People, Recycling in Peace. It's like a parallel universe where John Lennon is the small business owner, and the Environmental Watchdogs are the Establishment, and commerce with entrepreneurs in Ethiopia, Ghana, Egypt, Angola or Cameroon is a form of protest... like interracial marriage in the 1960s USA heartland. The mandated labels of "universal waste" which Vermont ANR proposes to put on collected computers and scrap metal crimps this trade with red tape. Dudes, it's like the reuse stuff is getting drafted into a shredder, and it's like "manchester england, england"... (song from Hair)
But maybe this is simpler than I thought... A solution to the "universal waste" dilemma occured in my dream. (And there's a very funny video below in the 1960's Label Theme)
We create our own paperwork. A label which says "For original intended use". Or ND- "Not Discarded". Or CDND - "Commodity - Do Not Discard".
It cannot be a hazardous waste or UW unless it is a waste (gasoline in your car is hazardous but is not a waste... it is still governed by OSHA, DOT, etc. but not by disposal laws unless you dispose of it.)
(13) "Waste" means a material that is discarded or is being accumulated, stored, or physically, chemically or biologically treated prior to being discarded or has served its original intended use and is normally discarded or is a manufacturing or mining by-product and is normally discarded.
Paperwork is good (and sign posting is good) if it accomplishes something.
Putting a "waste" label on an object which may be suitable for its original intended purpose (e.g. a diplay device still capable of displaying) is like labelling a wounded person "dead" in a hospital record book. It's paperwork which will have to be undone later if you are good at your job and can save the life of the product or patient. It's more red tape for the morgue than putting the toe tags on AFTER the patient ceases to be alive.
Another source is the "Conditionally Exempt Generators Handbook", published by the Vermont DEC. Virtually every definition and label contains the words "spent" and "waste".
Plan C: we could declare ourselves a Farm. Vermont farms have specific protections from solid waste statutes. There is even language in Vermont Statutes specifically banning ANR from creating environmental rules for pesticides which are more strict than federal law. Ok. My ideas are getting worse as I continue.
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