Deliberate Falsehood About "Ewaste" and Basel

E-Stewards Abandons Morality
Basel Action Network released a newsletter today heralding what they hope is imminent passage of the "Ban Amendment" to the Basel Convention.   At least this DOES acknowledge that the Basel Convention does NOT currently require "tested working" or fully functional, and does allow repair and refurbishment... and therefore they hope to amend it in three years and close those options.

Aside from the acknowledgement of the current legality of these exports under the Basel Convention, what is their case for amending it and banning repair and reuse in the future?

According to BAN E-Stewards, it is because refurbishers (geeks of color) "often produce hazardous waste, which is responsible for inflicting tremendous harm on the citizens and environments in these nations."  It's because reuse and repair poisons people and pollutes the environment.
"Only recyclers meeting the requirements of the e-Stewards Standard are in conformity with the Ban Amendment, which stipulates that no hazardous waste, including e-waste, can be sent from developed to developing countries. This includes untested and/or non-working equipment exported for refurbishment or reuse, some of which is currently allowed under the R2 Standard. Refurbishment often produces hazardous waste, which is responsible for inflicting tremendous harm on the citizens and environments of these nations."
Logically, if it were true that the refurbishing and repair industries "inflict tremendous harm on citizens and the environment", then banning import/export from rich nations is not enough.  They should also be banned from repair and refurbishing of product in their own country.  And in America, reuse and refurbishment should also, logically, be banned.

Show us "tremendous harm" in Indonesia.  Show us the hazardous waste "often" produced by refurbishment.   Show us how the Basel Convention, as passed, needs to be amended due to a single actual case of poison.   There is absolutely not one shred of evidence that one iota of toxic release came from refurbishing, repair, and elective upgrade.   No such factory was found at Guiyu, and no material at Guiyu came from such a factory.  This is why the Convention (the international law currently passed) does indeed allow export for reuse.

The Worlds Most Polluted Places (TIME) are metal mines, not recycling yards.

History: Epic Everyday Waste

Watching History Channel's "Epic History of Everyday Things".   Coffee, canning, razors, mirrors, beer, etc.   And "Nightsoil" - the history of managing poop during the Industrial Revolution.

The Epic History program recalls the importance of things, the controversy of things, now taken for granted.  How Venetians kept all the glass makers on a small island (Murano), populated with assassins, to keep anyone from learning the trade secrets around glass.  Similarly, how coffee beans and seedlings were smuggled away from kings and holy men intent to keep the coffee a secret... and the pilferers built stone castle walls around the transplanted coffee bushes in South America.   How a $40k reward offered by Napoleon led to the invention of canning food, and how that made moving troops - and colonization - possible.

Cesspool-sewermenThe segment on the epic history of the flush toilet hit home.  The "Great Stink of London" occurred from rapid deployment of a new technology.

It begins with the old system of "night soil" workers, who had to climb into sewage pits (cesspits) at night to empty people's sewage by bucket and rope.   The nightsoil workers were paid 4 times the average wage - a "good job" if your definition is pay.  Then, there were "Toshers" who were unpaid, but had the rights to run their hands through the sewage for the profit of finding lost rings, coins, metals, and other valuables.

Then the flush toilet came to the upper classes in 1815.  There was no sewage system designed for the amount of water these used, so they were flushed into the same cesspits, which quickly overflowed into the rainwater runoff system.   Since it was just a few people who had the systems installed, no one made much of the fact that the toilets flushed into the Thames River, the same source of water they were withdrawing.  But within 7 years, the Thames River of London became so polluted, as the toilet access expanded, that cholera epidemics broke out over the next several decades.  The same epidemics occurred in the USA - H.L. Menken described the City of Baltimore as smelling "like a billion polecats" in the 1880s.

T. Crapper, Flush Toilet Inventor
The "Great Stink of London" made papers for river pollution and nastiness, but the connection between the poor sewage and cholera wasn't understood until all the nightsoil workers and toshers were well out of business.  The flush toilets made the job of harvesting nightsoil impossible.  But like modern shredders, they looked much better than the system they replaced, and displacing nasty tosher children was a the primary benefit to the snobby class - before all dysentery hell broke loose.

I'm not sure I have the writing stamina tonight to weave the historical connections between "e-waste" and human waste... but my recent series on river pollution (E-Stork 1-4) and tracing causes upstream, and the way industrial revolution volumes of waste (textile, e-, or human) deluged the workers' systems which had been working, they all fit here.

Anti-Globalisation = Racial Profiling

"Terima kasih atas menggambarkan pekerjaan kami sebagai teknisi. Kami tidak pencemar kecuali seseorang mengirim kita polusi karena kita tidak memiliki pilihan lain pembeli kecuali e-limbah. Kami adalah pintar dan aku bisa memperbaiki hal-hal IT tidak ada masalah."
The quote above was posted from a commenter to the provocatively-titled blog post (one of the BEST series) "Are E-Waste Advocates Racist?"

My company has repeatedly been accused of being "an exporter" by companies which "don't export".  If you don't marry, how could you possibly be guilty of spouse abuse?  This is the logic established by companies like GARB, which posted to our Youtube video over the weekend
"GARB has the solution to the ewaste problem. The closed cycle principle.  A must see." 
As required, I came, I saw it.  Hammermills grinding and chopping computers into little pieces that are then hand sorted by labor on an assembly line.   It's "the solution" if you are looking for two things:  elimination of screwdriver labor, and elimination of reuse.  Yum yum.  I feel so much better about mining lead, silver, and tin for my new Tablet or 80 inch video display.  Having people pick up chopped pieces is SO much better than removing screws and sorting the same metals and parts, with some reuse.

The translation of the opening quote (auto-detected as Indonesian language)
Thank you for describing our work as a technician. We are not polluters pollution unlesssomeone sends us because we have no other choice except e-waste buyers. We are smartand I can fix things IT does not have a problem.

Non-Toxic Stewardship: E-Waste's Consequences

Just a reminder...  Be careful what you wish for (or mandate).

Indonesia Komodo:   source of ROHS
When you replace toxics, such as lead solder, with non-toxic alternatives, such as tin-silver solder you might reduce the toxics going into lined landfills.  Hurray.

But you replace those (recycled content) toxics by mining tin from Indonesian and Malaysian coral islands, and by mining silver.  Silver mining is the number 2 source of mercury effluent into the environment (after #1, gold mining).

The point is that environmentalists have a moral and environmental responsibility to do their homework before implementing laws which do more harm than good.

My ecological friends have an inconvenient truth assumption, which is that if it's more expensive, it must be better.  Recycling is generally less expensive than mining, because it uses less oil (read:  less carbon) and produces less waste.

But if you tie that recycling up in red tape while managing metal mining under the easy rules of the General Mining Act of 1872, and then mandate use of a low-recycled-content feedstock (tin and silver), you just might be no better than the industrialists.

"Gee, you spoil all our conscientious fun."

IPAD: I Want My, I Want My QWERTY

Money for Nothing Keyboard
The Day After Black Saturday:  Family discussing whether they want an IPad.  Or similar tablet, Galaxy, HTC, etc.

Millions of obsolete and junk products arrive here at our "e-waste" morgue, so opinion may pass as insight.

The laptop is a display device combined with a very flat computer (motherboard-powersupply-drive-etc).  They fold together with a keyboard input device sandwiched in between.  Three old technologies designed to fit snuggly.  In my warehouse we are surrounded by Input (keyboards, cameras and microphones) Output (display devices, speakers and printers), and the storage and processing (hard drives, processors) which bent time and distance to connect us to each other at exponential speed and convenience.

A smartphone eliminates the keyboard, in favor of a combination of software and touchscreen replacements... that is speed and convenience because of its portability (cell phone tower).   We generally don't use the smartphone to compose reports, blogs, or letters once we are at home or in the office.

Nevertheless, there have been enormous gains in touchscreen technology and software, as well as in voice recognition.  The smartphone market has unleashed a lot of software codewriting energy.

I want my, I want my, I want my QWERTY....

Where Apple really takes advantage is the opportunity to sell software or apps in this rapidly developing no-keyboard touchscreen market.   Two decades of Microsoft commanding the ALT-DEL keyboard market left other software makers too far behind to leapfrog Microsoft.  The growth of that market, and the level playing field, gives Apple a big reason to bring the touch display into the home and office.

Buying a PC, you were buying a software support environment based on a keyboard input device.  Apple had successes (notably with Adobe), but if you bought a PC you were buying a much larger stable of software code  With the Pad (touch pad) technology, Microsoft does not have a big bench.  The rules are being changed for input devices, and keyboard is no longer king.

So the question I ask my family is, how much do you hate your keyboard?   Enough to spend $1000 to get rid of it?  And will you buy a peripheral for $58.99 to replace it?

I want my, I want my, I want my QWERTY....

For me, so far, touch screen software - while it has made great gains - is still a limitation I put up with as a compromise... driving, cell phone towers, and battery life make it an advantage to laptops.   

When I see people buy keyboard-attachments for their IPads, I really think they should take another look at the sub-$500 laptop and netbook markets.

The big change however will be how non-English software takes advantage of the curve in the software road for Input Devices.   When I see Guangdong Geeks bent over the QWERTY device (infamously designed to slow input so mechanical typewriter keys don't jam), I wonder...

  • Are Chinese programmers enslaved by left-to-right keyboards reprogrammed for modern Chinese?  (Chinese and Arabs write right-to-left)

  • Or do they mainly sit passively and read from the display device, and not input (compose) as frequently?

  • Or are they going to use the leveling of the playing field for new touchscreen software applications to do, as Apple hopes to do, and leapfrog Microsoft?

  • Or... is this IPad tablet an I-fad, because really we will miss and should like our keyboards?  We keep them despite the QWERTY origins because they fit the speed at which we think most productively?
There are signs that my younger generations think more quickly than I remember thinking.   Younger staff, my kids, they are very fast conclusion-formers... They TXT LOL.  Hemingway, Dickens and Twain they are not (though all those writers thrived by incorporating less formal speech into their characters).

For the near term, Adobe, Google and Sun Java have as much of a level playing field to enjoy from keyboard-free input devices as does Apple or China.  Palm might have, but the sale to ink-cartridge-maker HP was hitching to a pretty old racehorse.

So for the IPad... I'm making room for them in the warehouse.  Personally, I always try to buy things I can repair or have a reasonable warranty (or sell-for-repair market, as my HTC Evo proved to have), and which have a reasonably mature software market.  We still have a very large Toshiba CRT Television (HD) in my living room, one discarded from an audio-visual company which paid top dollar for it, as part of a conference-call room.  A pre-skype conference call room.

I want my, I want my, I want my QWERTY....

And as anyone reading this knows, my input devices are as important to me as my display devices.  Touchscreen inputs, to me, are like sign language.  I respect it, and thank God for Helen Keller.  But I don't see it as a primary vehicle to compose a work of literature.

I'm not photogenic enough to rely on video, and the bandwidth constraints of video broadcast in emerging markets are unfriendly.  Video is like a subway, it can get you to lots of places with lots of people.  But typing is like walking, I'm not giving it up for the subway.

(Someone soon will release the first ever Text TXT novel, and it will be crap... Opera via telegraph)

I want my, I want my, I want my QWERTY....

Foreign Recyclers Take Over the World 2008

Three years ago, my 8 year old son came back from a year in France, and reacquainted himself with my office while I took a nap.  He found a FLIP camera there, which I'd gotten back from one of the WR3A videoers (Peru, Cameroon, Burkina Faso, Egypt, Mexico, Malaysia, Indonesia, Baton Rouge, North Carolina, etc).

see below

Ink Cartridge Re-Use: Light and Heat

Readers know that I was indelibly marked by my experience in Zuhai, Nanhai, and Foshan China a decade ago.  When I came across a neighborhood, several city blocks, where all the printer refurbishers had been shut down, and saw the supressed emotions of the Chinese city official, I went a google-ing to find what had happened.  I found an AGMA press release about a partnership agreement between HP and the Chinese EPA, as well as a long (and misleading) article in China Daily about "poison" ink cartridges.  The AGMA press release disappeared, Orwell-style, when I asked about it.

As if the new inks are healthy, and the fake inks are poison...  The link between counterfeit ink and poison?  E-storks with photos of children, and white juju words like toxin and cancer and e-waste.

What has been poisoned is the well of public opinion on reuse.

The fulcrum between legitimate re-manufacturing of consumables (inks, ribbons, toner cartridges) and counterfeit (back in a fake OEM box) remains the most kinetic place in the debate.   I just discovered a blog by David Connett, editor of The Recycler, a trade magazine for used cartridge remanufacturing.

350 Companies were expected at the 9th ReChina Asia Expo last week in Shanghai.  If it's the 9th show, it means it's been organized since about the same time I became aware of the war on reuse.

The profits on consumables like printer ink are astronomical.  The patent wars and push on patent exhaustion doctrine could have long term and wide ranging effects.

E-Stork 4: It's the Journalism, Stupid.

From "precautionary principle", regulators defined export as an action with "suspected risk".  While a case can be made that the risk has been exaggerated, it's too bad that case is being made by me, a self-interested, partisan, biased exporter - one who has no editor and little time to proof-read (cutting too long posts into 4 parts didn't work in college very often, either).

I believe in dialectic, and the "marketplace of ideas", to bring the truth.  But I wish more professional writers would take interest in repair, reuse, knockoff, and tinkering - the true opposite of the "resource curse" in poorer but emerging markets.

The "suspected risk" comes from the same source that cleaned up the Blackstone River.  No, not the Saturday Evening Post.   But journalists.   Ethical journalism provides us a shortcut for proper due diligence, a reason to "suspect" risk.   Until or unless a river has been traced upstream to a repair and refurbishing factory, the journalist can "follow the money trail" and interview people telling both sides of the story.   They have the power to invoke or water down the "populist cognitive bias" against, say, interracial marriage.  Journalists may not be able to tell where our soul comes from, or where it burns when we die, but they have the power to interview people who CLAIM they know.

It's ok that we still believe in heaven and hell as a matter of faith.   As Chaucer said, a thousand times I've heard men tell of joy in heaven and pain in hell... but none of them has been to either place and lived to tell about it.   Faith and crusades are fine for spiritual upstreams and downstreams.   For rivers and environmental policy, we need science.  Journalists accepting statements like "80% of e-waste is exported", without a single fact or figure to go by in ten years, need to wake the heck up.

E-Stork III: Where Poisoned Babies Come From

Green Ned Flanders Stork Museum
Part III of 4:   Does it really matter whether the pollution in Guiyu China came from E-waste, or from iron mining, or from textile mills?

If we are responsible for the Stewardship of our own upstreams and downstreams, as seems reasonable, why take any risk at all?

Isn't it appropriate for us to use our buying and selling power to procure the best available services, providing the best possible standards?

If so, why shouldn't our society, in essence, assign a liability for bad consequences to corporations we buy from?  Why shouldn't we ourselves remain legally liable for anything we once owned?  This concept is behind the "precautionary principle", championed in Europe:
The precautionary principle or precautionary approach states that if an action or policy has a suspected risk of causing harm to the public or to the environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking the action. [wikipedia 2011.11.20]
If the individual making the purchasing decision suspects risk, and there is a vacuum or absense of scientific consensus, the burden of proof (liability) might dictate we should "avoid bad neighborhoods".  In the "absence of scientific consensus" we have reputation, news reports, green fingerpointing upon which to formulate our cognitive risk.  EPA enforcement cannot happen (in the USA) in absence of science.  Perhaps we need Watchdog organizations to boost our collective sense of liability.  Whether or not what we did was responsible for the watershed pollution in Blackstone, Louhrajang, OK Tedi, or Guiyu rivers, perhaps we need watchdogs who bark falsely, to keep us on our toes.

Or so said the lawyer for the boy who cries wolf...

Populist Cognitive Risk:   The "suspected risk" of the precautionary principle has boiled down to racial profiling.   Reputations of Africans for "waste tourism", "organized crime", burning computers they purchase for thousands of dollars after spending thousands of dollars to ship them over the ocean and through customs...  Given most Americans command of language and geography (most would place Mauritania next to Malawi, Madagascar, and Mozambique...), a photo of a sad child or sandalled woman elevates the "suspected risk".  A friend of mine in Massachusetts, a recycler of conscience, said to me that if there was even a chance that a computer exported wound up in Guiyu, that she couldn't sleep at night if a computer her town collected might wind up there.*

[see Bambauer, "Shopping Badly: Cognitive Biases..." 2006)

E-Stork II: Where Poisoned e-Waste Babies Come From

The first E-Stork post was a tale of three rivers:  Blackstone, Louhrajang, and Cape Fear.  Each poisoned river was traced upstream;  in each case, a textile mill was found.

When science sends journalists upstream, to witness the cause of pollution,  it's excusable to use a poster child baby in the story.  In the case of the Blackstone River, Saturday Evening Post stories about mill working children brought the pollution of the river into stark, cognitive risk.  Laws corrected the textile mills, and the rivers healed.

China's industrial revolution looks a lot like the Blackstone River Valley in the early 1900s.  Regulations may be ignored, but ignoring regulations is being documented.   This group of professors in China is bringing attention to an unpermitted steel mill (  They aren't using baby pictures, but they are generating attention by being viral on the web.

Consensus over regulation begins with facts and science, getting the upstream and downstream on the table.   Annie Leonard is right about demand for "Stuff" driving competition to cut corners.   But the WSJ is also right, that cheaper goods benefit the poorest people (both in manufacturing and consumption).  It's easy for the rich to assert that Cheap is Bad.   If it helps you sleep at night to wear certified organic wool, good for you.

EPA took an important step in 2008 to try to bring groups to the table to air out such a compromise, in what eventually was labelled R2 or Responsible Recycler certification.

E-Stork I: Where Poisoned e-Waste Babies Come From

Part I:   Just returned from a Middlebury College Environmental Studies Event... Zbignew Brzinski headlined a presentation on Fresh Water Shortages in China; Christine E. Boyle, a Fulbright Scholar from NC, presented on China's water policy.

China needs to get very serious about water.  The easiest way to conserve water is to charge what it costs to consume - or costs to DESPOIL it.  Whether to tax water at industry or to tax it at households...

Clean water policy has an important history in the USA.  The Blackstone River laws passed in Massachusetts in 1912 were a turning point for the industrial revolution.  The Clean Water Act of 1972 became important to the recycling industy, because it gave more value to recycled office paper  - because it was pre-bleached.  When the mills had to pay more to bleach fibers, office paper became more valuable.

E-Waste Watchdogs say a significant source of Chinese water pollution comes from primitive computer recycling.  At least, that's what we are told despoiled the river in Guiyu.  The allegation that most of that dumping came from imports from the USA has been largely discredited - Beijing alone generates 8 million pieces of "ewaste" per year, according to China Daily.

Irregardless whether the junk computers in Guiyu come from Chinese collectors, or from American non-e-steward recycling companies, polluting fresh water is unsustainable. As a former environmental regulator, I know there is one important step in investigating river pollution.

Arsenic in a water sample... it's normal to look upstream.

When high levels of arsenic were found in the West Bengal rivers in India and Bangladesh, it became one of the most researched rivers in the world.  The Louhajang River was  investigated upstream.   They found this textile manufacturing center was dumping dye, flame retardant, and bleach straight into the bloody river.

How E-Stewards Made Me Rich?

Confessions of an Exporter on "America Recycles Day"

Well, rich is a bit of an overstatement.  But here's why I should be happy about BAN being around for the past decade, if not as happy as other exporters they made even richer.

Robin Ingenthron, Caught in the Act of Reuse, 2004
A decade ago, the SKD (elective upgrade) factories in Guangdong Provice (China),  Malaysia, Taiwan, Thailand, and Indonesia were buying hundreds of thousands of CRT computer monitors per week - mostly from California.  BAN's first video, showing primitive recycling conditions in Guiyu, led Silicon Valley Toxics Coalition and other non-profits to believe that anyone Chinese who buys monitors is burning and breaking them.

This led to a system of subsidies on the west coast, where consumers are taxed to break (cancel) monitors so they cannot be resold in Asia.  California CRT monitor supply disappeard from the market, almost overnight, or had to be smuggled in a replace-CA-address-with-AZ-product campaign (see Monkeys Running Environmental Zoo, my most-read post ever).

Tested Working Monitors, back in the day
The Asian factories still had very high demand for remanufacturing display units in emerging markets like India, Egypt, and Indonesia.  Reluctantly, they raised prices and offered to pay higher shipping costs from companies like mine, on the East Coast.  California's shortfall brought booming demand to New York, Boston, and even floated boats in Vermont.

In my defense, I declared the good things going on and tried to bring BAN on board, but the pictures of good geeks of color doing good things with exported displays complicated BAN's message.  It was easier for most recyclers to tell American consumers that the importers were "poisoning children", rather than make the effort to distinguish between good and bad reuse and recycling.

GAO Report on Electronic Waste 2008

Back in 2008, I spent some time with General Accounting Office staff (Nathan and Arvin) who were researching NGO allegations that EPA was not doing its job enforcing against exports of junk electronics to poor nations.  "Why We Should Export our Electronic "Waste" to China and Africa" gives the background which is missing from GAO's Report.   But what about the report itself?  For people who never visited the big secret factories that buy and refurbish monitors, did Arvin and Nathan use forensics to capture the failures in the system?  Or did they simply pose a hypothetical - buyers WANTING broken and non-refurbishable junk - and inadvertently lead people to assume that was the norm?   Here's a blow by blow of the conclusions outlined in the report.

The Report, "Electronic Waste", had three conclusions, described in the Executive Summary (below).  My annotations below are intended as a crib sheet for researchers using the GAO Report to evaluate claims about E-Waste Exports.  What it failed to do was even consider the case that exports of used equipment are mostly good, sustainable, and better than not exporting at all.

• Existing EPA regulations focus only on CRTs. Other exported used electronics flow virtually unrestricted—even to countries where they can be mismanaged—in large part because relevant U.S. hazardous waste regulations assess only how products will react in unlined U.S. landfills. 
This is largely true.  EPA's CRT Rule does describe printed circuit board scrap as "scrap metal", using the same logic that recycling needs to be governed more like mining if secondary materials markets are to develop in competition with less regulated virgin mining.  But other electronics do flow unrestricted, to nations where they could be mismanaged.   The Report correctly states that TCLP governs disposal in landfills and little else.

Whether EPA should govern other electronics is a tougher question.  I do agree with the report that the focus on display devices seems arbitrary.  But there is also a slipperly slope into regulating cell phone refurbishing factories, plastic markets, wire recycling,etc... If EPA cannot get CRTs right, is expanding the mission to other fields of battle really part of the solution?
• Companies easily circumvent the CRT rule. GAO posed as foreign buyers of broken CRTs in Hong Kong, India, Pakistan, and other countries, and 43 U.S. companies expressed willingness to export these items. Some of the companies, including ones that publicly tout their exemplary environmental practices, were willing to export CRTs in apparent violation of the CRT rule. GAO provided EPA with the names of these companies at EPA’s request. 
I agree with the first sentence, but it is because EPA does not collect the three years of data demonstrating actual reuse, as required of exporters under the CRT Rule.  The rule does not only say one time notification, it also requires 3 years of records.   I've got detailed and explicit records of our shipments, and tried to build WR3A around enforcement of that clause.   But EPA never knocked.

More concerning is the Report's methodology, posing as buyers from different nations in trading websites I had alerted Arvin and Nathan to.  The test was a good idea.  But here's where it failed in methodology - they advertised they buy BROKEN CRTs for high prices.   That does show that many people will sell based on price alone.  However, it creates a false impression that anyone buys broken things at high prices.  The actual postings by ACTUAL geeks in those countries explain the age, testing, and other requirements for display devices, and do NOT pay for the broken ones Arvin and Nathan offered $10.   I wouldn't call it entrapment, but if there is an allegation that Chinese American students are paying Anglo American students to fail, and government finds that Anglo Americans are willing to fail grades for money, that does not mean that Chinese American students actually have any incentive or are in fact paying white students to fail.   Posting the "finding" without that disclaimer turned out to be reckless.
• EPA’s enforcement is lacking. Since the CRT rule took effect in January 2007, Hong Kong officials intercepted and returned to U.S. ports 26 containers of illegally exported CRTs.  EPA has since penalized one violator, and then only long after the shipment had been identified by GAO. EPA officials acknowledged compliance problems with its CRT rule but said that given the rule’s relative newness, their focus was on educating the regulated community. This reasoning appears misplaced, however, given GAO’s observation of exporters willing to engage in apparent violations of the CRT rule, including some who are aware of the rule. Finally, EPA has done little to ascertain the extent of noncompliance, and EPA officials said they have neither plans nor a timetable to develop an enforcement program.  
GAO assumes the 26 containers seized in Hong Kong were mismanaged waste.   WR3A was affected by that multi-container enforcement in Hong Kong, as many of the containers were diverted to other countries with contract manufacturing capacity - as China had.  The Hong Kong officials clearly say that tested working monitors are "waste".  They do so to protect new Chinese manufacturing, possibly in violation of the Doha Round of WTO on cores, remanufacturing, and reassembly.  China never claimed the CRT containers were "half full" or "half empty"... China bans perfectly working monitors.

The Chinese factories no longer really buy working CRT monitors from the USA.  Some of the factories are still operating, on a smaller scale, but they largely refurbish monitors sourced less than an ocean away, in China, Korea, and Japan.

What is central is that GAO did a fairly good job in this report of narrow criticism of EPA, TCLP, and enforcement practices.  But GAO was caught in the passion whipped up by photos of poor children, used to describe Geeks of Color who were running huge remanufacturing and white box equipment factories.

Yes, Chinese, Pakistanis, Indians, Indonesians, and Africans buy used equipment.  Yes, Americans and Europeans throw away used equipment after a couple of years of use.   We need data, how much of this equipment is burned or repaired.  The studies so far, in Peru and Ghana, show that Geeks and tinkerers in emerging markets are willing to take only so much "toxics along for the ride", and are a lot better than the primitive wire burning villages which have been mythologized by angry liberals.  History needs to record that 80 percent of the exports of CRTs were proper.  The glass was 80% full.

It makes more sense to ban abortion if you can show that 80 percent of abortions end in death of the mother.   But posing as a bad doctor does not prove the statistic.  Recycling should be safe, legal, and transparent.  Visiting the factories in China was just not convenient for GAO, and posing as a stupid factory that cannot write a purchase order did not work as a short cut.

Black Leg Mining Song

The recyclers in poor nations today seem to have inherited the untouchable qualities, distain and attitude of consumers, of the miners that preceded them.  These "black leg" miners were white.

Regulatory Nuts: To Approve Reuse of Waste

There are peanut allergies.  People can die if they eat a peanut by mistake. [Peanut Allergies Over-Reaction]

At the same time, there is a peanut shortage [Soaring Peanut Prices Hurt Food Banks]

Looks like a job for government regulators.  (I've been on both sides, with a decade as both a regulator and a decade as a private business and a decade in the non-profit / activist sector).

First, at the point the peanut is harvested, you put in rules against harvesting bad peanuts.  Ok, this really has nothing to do with deaths from peanut allergies, but you've been called and it doesn't sound unreasonable.

Peanut Stewardship:    Second, you institute a state procurement plan to pay for destruction of bad peanuts.  You've been told it's really expensive to remove bad peanuts.  So you tax peanut butter, peanut oil, the producers of new peanut snacks, to help pay for the inspection and removal of bad peanuts.

Now, since the peanut collectors are getting state funds (from peanut butter tax), it's reasonable to require more rules and regulations of these nut collectors.   In addition to the rules for what happens to bad peanuts removed through the subsidy program, you add a line about what may happen to the good peanuts.  Surely it's reasonable to track them.

The easiest way to regulate this is to declare all peanuts "bad" or "waste" or "p-waste", and then to set conditions under which they can be "de-wasted".

Local P-Waste Reuse:  You want to know how many peanuts are eaten locally.   Vermont is a small state with porous borders.  Since trucking is harder to track than you thought, you define "local" as the "United States of America".  If the peanuts are sold to Florida, California, Texas, Alaska or Hawaii, they must be tracked.  Define "local" as USA.

An anti-externalization/anti-globalization activist/watchdog suggests that sale of good peanuts could still be a loophole for export of bad peanuts to countries with little infrastructure to deal with them.  "Up to 80%" P-Waste exports result in crying children photos..  Regulators are paying so much for the bad peanut destruction, that would be a terrible loophole, a shame, if some bad peanuts were labelled good peanuts, and paid for by exporters instead of charged to the state subsidy... it would be a failure of the whole state subsidy program if bad peanuts got through.

Again, you don't actually have the authority to under RCRA Waste regulation to seize or regulate good peanuts.   So you define all peanuts as 'pwaste' even if they are not charged to the bad peanut removal program (because they were good peanuts).

Although they are not charged to your bad peanut removal program, the good peanuts must be tagged as "p-waste" at the point of collection.  They can be "un-wasted" if they qualify as good.  This is how you capture Reuse under RCRA, which has defined reuse not to be waste.

You institute a toe-tag label program.  Every single peanut collected in Vermont is labeled "p-waste", so that you maintain the authority in case a bad peanut is labelled a good peanut.  Do not tag bad walnuts, bad almonds, stones, dirt, roots, or  as waste, as these are not "covered nuts".  Not all waste is "p-waste", and not all "p-waste" is waste, and not all p-waste is covered by the subsidy...  clear enough.

Now, to define how good peanuts, not charged to the program, may be used.  Some good peanuts go into peanut butter, some go into peanut oil, some go into snacks.  You now ask the collectors to identify whether the peanuts are going into a snack, an oil, or a butter.  The collectors and farmers explain they don't know, they sell peanuts to a peanut buyer who grades and processes peanuts for sale.

To simplify, since the farmers are allowed to sell for "local" use, and most local reuse in Vermont is for snacks, you define local use to be snacks.  You then write a rule that the collectors can only sell peanuts to snacks, and that if sold as snacks, they cannot be charged to the bad peanut program.  But first they must be tagged as bad peanuts, so that snacks do not become a loophole for poisoning people.

This is not a game.  Remember, environmentalists have pictures of poor children.  People die.  The ebattled regulators have been accused by watchdogs of being pushed around by peanut collectors and processors, you need to demonstrate you can regulate this.  Be firm.

Now, peanuts sent for non-local reuse can be defined to be butters or oils.  You now need a plan from the peanut buyers, the ones who process peanuts for sale to oil, butter, and snack manufacturers. You don't want to complicate the paperwork you've created, so you ban the processors from selling for "local use" (forgetting you have defined the USA as "local", or perhaps not caring, or perhaps just living up to the laws you've written - its a thankless job).

If a peanut is sold as good to the "export" market for oils and butters, it must have been tagged a "waste" but must not have been charged to the "waste" program.  The professional peanut processors complain that selling perfectly good peanuts labelled as "waste" violates the health laws of the importing nation, which is trying to keep bad (waste) peanuts out of their products, and bans use of "waste" peanuts to make butters and oils.  Cleverly, you see this is an attempt to reopen the loophole, and must stand firm.

Now, the processor must define a plan for the export of "un-wasted" peanuts, regulated but not charged to the waste peanut program.  The plan needs to account for whether peanuts are sold for oil, waste, or snacks.  Is the shell removed?  Explain how the shell is left intact for the snack market, or removed for the butter market.  What?  Some snacks, such as candy bars, remove the shells?  Simple, just explain that in your plan so that sales can be approved.  Stop complaining.

Wait.  The bill you sent for waste peanut destruction shows that some peanuts have been removed.  While there was a plan and an understanding that peanuts would be removed for use, the missing peanuts must be labelled and tracked.  That is, in addition to not charging for them through the waste peanut program, and selling them only through a certified non-local (export) oil, butter, or snack program, you must INDIVIDUALLY account for the peanuts removed from individual bags of "p-waste".

All in all they're all just bricks in the wall
The processor tries to explain "triage".  The people like collectors or sorters are trained to remove bad peanuts.  They are not trained to know which peanuts are best sold for candy bars, peanut oil, or crunchy style or smooth peanut butter.  That happens at the buyers, or according to the purchase order QA/QC of the buyers.   Oil buyers have a different specification for "good" peanut than snack buyers.  In fact, a perfectly tested working peanut might not be right for the individual snack, oil, or butter factory.

The fact that a shell-on peanut is not accepted by the oil factory does not mean the shell-on peanut was "bad", but it will become "waste" if you send it to someone who doesn't or cannot shell peanuts.  This is the same fallacy of "tested working" and "fully functional" computers, they are not all acceptable at the best buyers.  Because your solution didn't work for them, that doesn't make them bad people!

Heavy Metal Toxic Farms in China

It's the Mining.  Not the Dumping.

In the USA, 45% of all toxics produced by all USA industries comes from non-ferrous metal or hard rock mining.   Copper, gold, silver, lead, tin, etc.  Whether or not the metal is toxic, the ores exude other toxics, and toxics are produced by treating them.  Gold mining, silver mining, and copper mining are three of the top 4 sources of mercury pollution in the USA.  The third on the list is defense industry.

Similarly, in China, this study shows that toxic on farms is not imported.  The bulk of the toxics come from the opposition of recycling - mining, refining, digging, smelting, virgin material industries.  These are the opposite of recycling.
Wan Bentai, the chief engineer for China's Ministry of Environmental Protection, said heavy metal from smelter chimneys, water run-offs and tailings has polluted in total about 10 percent of the country’s farmland, and the pollution levels have exceeded government limits, according to Southern Metropolitan Daily.
"In recent years, there have constantly been outbreaks of heavy metal pollution, and from January to February alone there were 11 incidents, nine involving lead," Wan said in All-China environmental NGOs sustainable development meeting in Guangzhou, Guangdong Province.
The most toxic places on earth, including Africa and Asia, are from virgin mining, the same industry that creates "conflict metals" and leads to bushmeat trade.

Yet, whenever there is a story about "toxic lands" in China or Ghana, the environmental community jumps to the conclusion that it is A) recent, and B) imported.

Mexico is Family Visa Policy

My Insights into USA's Immigration and Guest Worker Policy with Mexico

American Retroworks Inc. has a sister company in Mexico, retroworks de mexico, nicknamed "Las Chicas Bravas".  It has been profiled on NPR Marketplace, Living On Earth, Associated Press, Sacramento Bee, and many other media.  My wife and children come with me to visit the ladies at the TV maquila in northern Mexico.  While our attorney was shot and killed, we never see any drugs or violence in the rural town of Fronteras, a few dozen kilometers from the mines and smelter of Nacozari.

We regularly cross-train workers from Mexico, like Mariano, Dolores, Vicki, Lydia, Panchito, Dominita, Don Chuco, etc. at our plant in Middlebury, and they cross-train our staff during regular visits to Arizona.  We recently sent Nate Hutnak, our collection partner in Rhode Island, to Arizona to help establish collections. My business partner and his wife visit us, and host us, and my kids are close with their godson Oscar, who spent a year with us in Vermont and Arizona.

Mexico is our Family
Mariano from Mexico tests and inspects and sells fully functional TVs, and occasionally brokers them to buyers in Peru, Venezuela, or Guatemala.  He cross trains Vermont staff, some of whom were born in El Salvador or Honduras or Guatemala.  In short, our fair trade company has partners in many countries, from Burkina Faso to Indonesia to Egypt and Senegal - but Mexico is family.

Our key policy is that manual disassembly creates more value in parts, and more jobs, than automated recycling.  We do manual disassembly in Vermont... but if you are going to create low wage demanufacturing jobs for Mexicans, it's wiser to make those jobs in Mexico.  Our competitors try to chop TVs up with machines, but believe me, running electronics and e-waste through hammermills and shredders is literally not all it is cracked up to be.

Having established my personal bias and credentials, what can I say about national USA policy on border enforcement, illegals, green cards, work visas, and immigration?  Here goes...

Basel Action Network Agrees: Ghana Is Good

The Report from Ghana showing 85% reuse - not "80% primitive dumping" has finally taken traction.  People are wondering what is going on.  Basel Action Network had previously, repeatedly, claimed that 80-90% of the used electronics imported into Ghana were "toxic junk".

Last week, BAN tried to "spin" the report in their blog.  They announce it as "just released" (I spoke to them about it when it was released in April).  But perhaps they've now had a chance to review it.  Mike at BAN describes the study as follows:

The Environmental Protection Agency of Ghana just published their “e-Waste Country Assessment,” based on actual data from Customs authorities, field visits and meetings with key stakeholders — that is, from credible, in-country, official sources...

Ghana reports that at least 35% (and perhaps much more) of imported, second-hand electronic and electrical equipment (EEE) is non-functioning, most of that coming from the EU and the USA. Some is repairable — but fails soon and adds to Ghana’s growing e-Waste crisis.
The functioning equipment does create opportunities. But the dumping and burning of the rest results in serious consequences on the environment and a threat to public health. “Even children, sometimes as young as 5 years old, were observed to be involved in the recovery of materials from WEEE recycling, earning less than US $20 per month.”
BAN tries to impugn the repair market by including material documented as being professionally repaired in the "unacceptable" category, boosting the bad export number to 35%.  It is still LESS than HALF what BAN has told reporters.  And the repaired material is not described as "fails soon"... and the report says nothing about "(and perhaps much more)".

This post from BAN completely agrees with everything I've said.  Exporting more than 1/3 "waste" to Africa is economically impossible.   While I disagree with including "successfully repaired" with "waste", and think 15% is the problem, I'll concede for the moment that one third may be bad.

This now puts BAN in my corner about "waste tourism".   I now invite BAN to agree with me that the Europol and Interpol reports which describe African screeners (who buy and source the equipment in Europe and the USA) as "waste tourists".    I now invite BAN to join me in declaring the Europol conclusion that "organized crime" is behind the exports to be racist, bigoted, hogwash.

Next, if we can agree that the "problem" is somewhere between 15% and 35%, and that most of the waste being burned in Ghana's dumps was imported decades ago and was in active use for years, can we not also agree that the good part of the imports - 65-85% - should be continued?  Can we not use the economics to generate fair trade solutions, giving incentives for the repair markets (like the one EPA Lisa Jackson visited in Ethiopia) to become take-back and recycling programs, like our WR3A partners in Mexico and Malaysia?

Thank you to BAN for addressing this important study, and for admitting that MOST exports to Africa are good people trading good things with other good people.  Now, can BAN take the next step. and publicly denounce "no intact unit" as an export standard?  The percentage of "waste" in shredded equipment is higher than the percentage of waste in repaired equipment.   E-Stewards should not be allowed to destroy working equipment?

I'm going to invite BAN representatives to present with me at a Sustainability Forum here at Middlebury College.   They can meet geeks of color like Wahab of Accra Ghana, Oslo of Egypt, Ow Fung of Malaysia, and Jinex of Peru.  Looking the Technicians in the eye, and saying you now understand they are not about "80%" e-waste, that they are not "primitives"... Maybe BAN can help my friends to source even BETTER material, and more of it, and to join us in Fair Trade Recycling.  Maybe they can donate equipment to our UN partners, or to Meltwater Academy?  Neil of Cascades, a fellow RPCV, could moderate.

Join me?

Plan Do Check Act

Poster Child, Toxic E-waste
At the California Sustainability Directors conference last summer, I was pinch hitting as a representative of R2 - Responsible Recyclers standards for "e-waste" recycling.  I was hastily invited by someone as a counterweight to what was originally a purely E-Stewards presentation on certification.

When certifications compete, it's a bit like warring doctors or feuding priests.   Both certifications were set up less than 18 months ago, neither has really been tested in the field.  Either may have unintended consequences.  It's only the second inning.

Both certifications are overseen by professional auditing bodies - ANAB and ANSI, the same which authenticate ISO, RIOS, and other standards and practices.  These bodies are designed to check on whether the standard is independently verifiable, legal, and can be implmented via PDCA - Plan, Do, Check, Act.  The standards are so similar in many respects that the auditors can use the same pages of verification interchangeably to ensure that the companies applying for the standards meet the same environmental, health and safety laws.   None of the standards have an in-house auditor playing Catcher in the Rye, catching children from falling into toxic fields.  PDCA is better than nothing, but it is weaker than a civil law contract.

How then do the certification advocates differentiate between them?  Marketing.

The groups which are invested in the term "e-waste crisis", the ones who would use prohibition in trade with techs of color as a solution, are using drama, guilt, innuendo and poster children to attack the other groups best efforts to promote best practices.   They treat companies seeking R2 as the new evil exporters.   Seeking to do good without the ayatollah's blessing leads to ayatollah cursing.

In describing "responsible recycler" practices in their Wikipedia article on "E-Stewards", Basel Action Network tries to poison the well on the term:
Jim Puckett, director and founder of BAN, said: "Sadly not all of those companies that call themselves responsible recyclers are truly responsible and many are not recyclers at all, but are just exporters. We have been to the techno-trash dumping grounds of Africa and Asia and seen the children being poisoned. This is why we created the e-Stewards Certification in the first place."[3]
Jim made a similar accusation, in an editorial he published in 2009 E-Scrap News, that "fair trade" recyclers were "poisoning people".  He claimed to have knowledge that containers of refurbishable equipment imported into Indonesia was "hazardous waste" (same claim we are still waiting to shake out from his accusation against Intercon Solutions of Chicago Heights).

The marketing against a standard developed to improve e-waste trade is obnoxious at best.  The R2 "Responsible Recyclers" program represents a two-year consensus document approved by regulators, NGOs, and industry, not "just exporters".  It is the association with possible exporters which poisons all the other R2 certifications, according to BAN.   "Exporting" according to BAN, simply means poisoning children, not creating internet cafes in Africa.

Poisoning the well for alternative certification standards does not just affect the exporters or users of a particular practice.   Consider the effect on R2 companies which do not even export.   If you are R2 certified, even if you do not export, you may share a certification with someone who does export.  And that exporter, while they have been certified for proper and legal exports, BAN implies may be poisoning children...   You may be R2 certified and use no prison labor (most do not), but because a prison program can seek R2 certification, wham!  You are not the same as a prison program.    Someone who goes to a church which allows gay marriage is the same as someone married to a gay person... at least, that's the same logical thread.... Joe McCarthy reincarnate.

Just how big is the risk that an exporter "among" the R2 may be poisoning innocent little babies?   BAN is silent about the major study released on Ghana's imports of used computers, showing 85% reuse.  Why?  Why do professional AID workers, Peace Corps volunteers, and development officials applaud the same fair trade recycling importers in Africa which BAN says are poisoning children?  Why would stakeholders from NGOs, EPA, and industry "collude" on an R2 standard which kills children with e-waste?   Nevermind the fact that almost all the exports come from Europe and not the USA (BAN applauds the EU's higher standards).

When someone is promoting something, marketing it in this way, there's one common denominator.

Follow the money...  the difference between R2 and E-Stewards is payola to BAN... not a dime of which goes to help a single African baby.