Environmental Anaphylaxis: Auto-immune Attacks by Environmentalists on Harmless Africans

This is another "Environmental Malpractice" blog.  And it's not an easy read. Some may decide to ignore it.  But the number of people who "get it" is steadily increasing.  This summer another major player "took the red pill", and realized that "saving Africa" is not accomplished by impugning motives, environmental balance, or skills of Africa's "ewaste" Tech Sector.  In this blog I try by analogy to connect the #whitesaviorcomplex, #charitableindustrialcomplex, and #environmentalmalpractice to greater liabilities and inefficiencies in societal systems designed to cure flaws - from affordable housing, to peanut allergy, to snakebite kit sales, or to used car sales in Eastern Europe... 

It's all about bringing Stewardship Advocates to practice Stewardship (liability) for their own regulatory systems, to do no harm, and when they find out they have been harming, "adjust course".  It doesn't require a mea culpa if you do the right thing from now on.

Last week I was alerted to an editorial by Laura Seay and Alex de Waal (July 17)

This was via a tweet from AfricanSolarLLP, a boots-on-the-ground solar energy project coordinator based in Accra, Ghana, who (along with Alhassan Abdallah) has been bringing first-hand accounting of the Old Fadama / Agbogbloshie real estate evictions (vs. "Sodom and Gomorrah") via @Twitter.

TASC‏@AfricanSolarLLPDo-gooders, do no harm: What are the best-and worst-ways to help those mired in international conflicts? http://wpo.st/jX-R0 

The article (Q and A) addresses many of the cautions I've undertaken, and there's some heavy stuff to dish out to readers of de Tocqueville.  An increasing number of environmentalist intellectuals like myself, may remain ardent environmentalists, but still fear the "churchiness" of the environmental-regulatory complex.  This is also true of other "world savers", we can be ardently pro African while suspicious of what Peter Buffet called the Charitable Industrial Complex.  In fact, much of it could apply to Fair Trade Recycling, and is a reminder of the dangers in heroicizing our "geeks of color" and "hurricane bensons".

Making more people aware of an injustice by oversimplifying the problems and the remedies is Poster Child Policy.  Making sad photo-essays of orphans working in scrap yards, and representing those children to be "emblematic" or embodiment or archetypal of African importers, is wrong on the science, and leads to environmental malpractice.

The challenge is to neither write so densely that no one reads it, nor so simply that it sets people off with the equivalent of racial profiling.  Basel Action Network "simplified" the long and complicated Annex IX, B1110 rules on export for repair and refurbishment by telling virtually everyone that it meant "fully functional", creating a set of enforcement guidelines which Joe Benson eventually gave up and pled guilty to in return for a decreased sentence.  [NOTE: That is not "twice convicted of the same offense," the just-world-fallacy / panacea shared by CWIT].  But at the same time, we have to recognize that progress has been made in understanding the nuance of "ewaste exports", and I think I can report that arrests of other Africa Tech Sector geeks like Joe Benson are less likely.

The awareness of the misuse, and misapplication, of well-meaning guidelines should serve as a broader lesson for all environmental interventions.  First, do no harm.  Protection of the innocent takes precedence over the simplified profiling guidelines (what Emile Lindemiller of Interpol called "Proactive Enforcement" - get out there and accuse people before the crime has been committed, and less environmental harm will occur.

That's like giving snakebite kits to everyone and telling them to incise and suck out the venom, whether you know the snake was poison or not.

I'm happy to report that Interpol staff may not be electronic repair experts, but I'm reassured they can eventually see when their enforcement is being abused by interested parties.  Eventually, they will get it right.  What environmentalists need to learn is to take responsibility for our stewardship and environmental dumping enforcement "cures" before a proper diagnosis has been reached.

This is how the study of environmental health must learn the same lessons as the application of western medicine to promote human health.  It's ok for a doctor to make a mistake, a mistake is not malpractice.  It becomes malpractice when you have been provided information to correct your practice and don't follow it.  This is the pivot point.  We don't blame NGOs or Interpol for believing 80-90% of used computer purchases by Africa's techs were for "primitive burning" when they actually believed it, and were told so by the press.  Once the source of the statistics has been discredited (and we can safely say we are at that point), it is the way the agencies - International and Non-profit - comport themselves going forward which matters.





I had a meeting with international enforcement staff (Interpol).  Now as a reminder, I'm a former regulator and I did a semester at the UN / Geneva Switzerland in 1983 (on the Infant Formula / Nestle Boycott movement in the UN General Assembly).  Let me just say that getting European based international staff to say publicly that a correction is in order is about as likely as getting Ban Kee Moon to publicly endorse Donald Trump for USA president.  This is not a criticism, but the loyalty is first and foremost to the Agency.  If you believe your agency's credibility is important in the "bigger picture" or "long run", you are doing your job not to emphasize a mistake (say, importing dysentery to earthquake vics in Haiti).  And I recognize that meeting with a wildcat blogger like me for a long time is worth more than a handshake.

So I won't kiss and tell, but I think Interpol "gets it".  It took awhile to wade through all the studies.  But if you have sent officers into the field chasing 80-90% criminal dumping, and find it's 10-20% dumping, and that 10% damage in shipping, damage, elective upgrades, etc. is common to rice exports, electricity generators, farm tractors, etc... you can resent having been used politically by, say for example, charities,  EU metals buyers, big shred, planned obsolescence, etc.  If hypothetically you recognized the "Dennis Moore" analogy, and distribution of justice was "trickier than you thought", you don't want to damage the Agency through a correction.  But you might find a way to let the blogger know you "get it".  Imagine a Matrix movie where a silent majority has all taken the "red pill" and all realize it's an elaborate illusion, but choose to walk around in it.  That's what the #ewaste policy world is beginning to look like.

USA EPA, NGOs, international staff, are all increasingly signalling to me that they "get it".  They don't want to be blogged about.  But the Emporer of E-Waste has no clothes, and a lot more people see the naked exploitation of the enforcement system by "interested parties".

This is not to say that "environmental externalization", the theory of unintended effects of environmental enforcement in (e.g.) OECD nations (or localities within those nations, via "environmental injustice") is not a genuine issue.  It is, in the same way that housing and zoning are legitimate issues.  But having created a "solution" for the problem, we must be "stewards", responsible when that solution veers off course, or is itself - like environmental regulations - a source of unintended consequences.

Growing understanding of Nuance is a kind of "cold comfort" to Hurricane Benson.  A UK Environmental Agency may slowly realize its aged leader Lord Chris Smith drank the wrong kool-aid, but those looking to preserve the agency - which certainly has more merits than demerits - doesn't want to fan the flames.  And I've been "flaming" them pretty hard.  But kind of like the Catholic Church at some point recognized it had "a sex priest problem", there's an increasing awareness of the "nuance" of arresting Africa's Tech Sector based on photos of goods at dumps that were exported 5-15 years earlier.

Junk 1980s Volkswagens in Romania don't prove that Germany dumped its "a-waste" (auto) on Eastern Europe.   Romanians know that Romanian car engineers had to be pretty resourceful and crafty to keep cars running behind the Iron Curtain, and know that Poland and Ukraine and Slavs imported a lot of used cars from Germany as soon as the Berlin Wall fell.  They can identify with the technicians at Chendiba Enterprises of Ghana who import used computers, service them, and bring Ghana double and triple digit teledensity growth for two decades.  They know that Mike Anane collecting asset tags anecdotes doesn't prove sea containers are dumped in an auto scrap yard.

So the good news is that I believe Interpol "gets it" and I believe there has been a paradigm shift.  It hasn't reached the mainstream press or the photo-journalists yet.  But #ewastehoax is headed to a quiet "correction".  Project Eden may continue, but they are looking for Trafigura, not for Lagos TV repair technicians or other #geeks of color.

So what's the big, long-essay, next step?

My life philosophy is that we need to repair failures in our own environmental movement.  That when we design carrots and sticks, grants and enforcement, to correct real problems that need to be corrected, we have the same "Stewardship" responsibility that we demand of Manufacturers.  If a manufacturer designs a product or system that does harm, we need to tell them to do no harm.  Likewise, we need to be responsible for our own "Stewardship" command-and-control systems.  We too need primum non nocere, "to do no harm".

Much like curing cancer, or rather an auto-immune disorder.  When we send enforcement and "certification" staff out to "correct problems", we need to recognize when they are "attacking healthy cells".   If we invent an injection for peanut allergy response which costs $500, or 100 times the cost of a Benadryl capsule, we need to recognize the slippery slope...

At the Mayo Clinic website, you start to recognize a lot of "can include" and other modifiers.  You learn all kinds of things about Epi-pen, the $500 emergency injection.

Anaphylaxis: A life-threatening reaction

Peanut allergy is the most common cause of food-induced anaphylaxis, a medical emergency that requires treatment with an epinephrine (adrenaline) injector (EpiPen, Auvi-Q, Twinject) and a trip to the emergency room.

Anaphylaxis signs and symptoms can include:

• Constriction of airways
• Swelling of the throat that makes it difficult to breathe
• A severe drop in blood pressure (shock)
• Rapid pulse
• Dizziness, lightheadedness or loss of consciousness

But you don't quite get the answer a parent needs when a child is having a moderate episode.  The Huffington Post had a rather brave article in 2013 that pointed to a study that only 13 deaths from peanut allergy had occurred between 1996-2006.

Now I'm NOT going to wade into the peanut allergy water, but use it to illustrate how the fear of liability, or fear for a child's life, can impact a decision to use the epi-pen.

If you see your child has a moderate breathing difficulty, and you don't use the epi-pen, the statistical chances are that the breathing difficulty will abate.  But it's the odds vs. the stakes.  And what if you are taking care of someone else's kid, who has an epi-pen?  You aren't an expert, but you see the kid is having a bit of a panic attack and you probably are not far behind.

Most people would say, err on the side of intervention.  Give the dose.  Because the liability for not giving the injection has a future value of more than $500.

But what if millions of people are making this decision, for a few hundred actual severe cases of severe anaphylaxis?  At some point, you have to ask the question... why do they no longer sell "snake bite kits" at camping stores?  Because studies found more people died of complications and infections from the snake bite kits than died of the snake bites.   In 1998, there was a massive Epi-Pen recall [WSJ] of nearly 1 million peanut allergy injectors, worth $1.4M.  What if you were told there's a liability for a risk of using the epi-pen?

The auto-immune discussion may be opaque to some, but I think it reflects the realization that "80% of used electronics sales are illegally dumped" (still widespread, recently hocked in press releases from the UNEP to promote a report saying only 1/3 of seizures showed ANY allegedly illegal shipments.  That's not saying a different report refutes the headline - THE REPORT ITSELF REFUTED ITS OWN HEADLINE.

So Lord Chris Smith's UK Environmental Agency has been sent out to profile African Used Goods buyers - and again these are AFRICANS doing the export and import, not cartoon money-hatted Annie Leonard Story of Stuff cartoon, Montgomery Burns Sham E-Waste companies.   Their enforcement directly benefits UK's Big Shred companies, and "keeps valuable scrap metal" in Europe.  It serves the work of Planned Obsolescence and anti-gray-market manufacturers.  And it boosts a budget for charities and NGOs and European bureaucrats.

So the fact - FACT - that 90% of the used goods imported into Africa are working or repaired is quite different from the allegation of 90% waste.   In this derivative mind-blowing matrix, the anti-immunity disorder is the Agency.  Imagine millions of schools being distributed Epi-pens, which were incorrectly administered 2/3 of the time, like a snakebite kit. Oh, wait... don't have to imagine half of that.

Now imagine that it turns out that the best way for Africa to develop, and to develop its own proper recycling infrastructure, is to allow it's Tech Sector to become a Steward.  Instead of trying to prevent the Tech Sector from acquiring affordable goods, instead of preventing repair and refurbishing jobs by cutting off their supplies, that you discount the sale price in order to incentivize takeback... to involve the Tech Sector - Africa's best and brightest geeks - to oversee Africa's bottom rung recycling/scrap sector.

It would almost be like discovering that slowly eating more and more peanuts is a better cure for peanut allergy than sending ill-trained school marms out with $500 epi-pens.  Oh wait... that is what they discovered this year [Huffington Post 2/2015].

Instead of arresting Hurricane Joe Benson, the UK Environmental Agency should be giving him a grant to take back any accidental breakage or 15-year obsolete goods generated by Africans.

That's the Fair Trade Recycling model.

What Environmental Studies needs is 3.0.  We need to study a holistic approach to world environmental problems, not a million dollar grant to send braggy exaggerating white people into Accra's notorious urban land development politics.

More below, my thoughts on 3.0, the need for intellectualizing do no harm.  And another analogy - this time on the urban and suburban land values and the "ghetto effect" of USA housing policy due to racial profiling... and how Africa is going through the same things with linguistic and ethnic and religious minorities (Dagbani, Hausa, etc.) that America cities went through with blacks, when housing projects were cited away from white schools, creating a later need for busing.



I just heard NPR Fresh Air podcast of the history of USA public housing policy by Richard Rothstein (how real estate agents interested in white property values remained more interested and stubbornly involved in public housing and zoning) and this is going to be a fairly long haul... Interpol's Project Eden will be sunsetted quietly, but it was not the "root cause" of Hurricane Bensons (plural) arrests.  

My long held belief that environmental enforcement is aimed at protecting property values is reinforced.  The wealthier the geography, the more regulators.  Regulation that drives "externalization" decried by environmentalists, and that financial interests will continue to take advantage of any "rules".

The challenge we all face is to make justice digestible.  The hopeful thing is that Interpol folks eventually figured out they are being manipulated by European metals buyers, Big Shred, and Planned Obsolescence, what they wanted me to convey to you guys is that intelligent people with our level of insights (that's grouping me with whom they labelled "the academics") need to simplify and focus objections earlier and faster.  Basically they were frustrated at the 2011-2015 period when photojournalists and Basel Action Network were in the drivers seat because no one was mobilizing the correct information in a way that was accessible to journalists and non-technical governmental staff.

Coming from 3 generations of journalists/journalism professors, I'm reminded that the number of people who read the "corrections" (page 2) is always a fraction of the ones who had read the juicy headline.

I realized this was at play in 2008 and began trying to fight fire with fire.  What I would like, looking forward, would be for our project to deliver some defense of the "autoimmunity disease" when environmentalists and regulators are turned against basically good people.  I've been somewhat heroicizing the "geeks of color" and "hurricanes" but as you guys probably know that's

Blacksmith (Pure Earth) has taken a very rude stance but wants to sunset Agbogbloshie (wait for the news to go away) and move on to other things.  It's not that gratifying, but yes hopeful in the way that ending desegregation was hopeful.  I forsaw the tensions when I contact them in 2013 and 2014, and now in 2015 they find my blogging too aggressive to meet with ANYONE from WR3A.  They won't meet Emmanual Nyalete, or Wahab Odoi Muhammed, or anyone at all about issuing a statement correcting Jim Puckett's citation at EScrap News that Blacksmith / PureEarth is behind the Agbogbloshie hyperbole.  And it's not because they don't read EScrap News - they asked EScrap to ask me to edit a comment I left about the blog, and when I edited it to be nice, said that EScrap had agreed with them.

Bullshit.  This is not how holy organizations address their problems.   Environmental Malpractice needs to be taken as seriously as medical malpractice.  Africa's Tech Sector -- and many other recyclers - have been harmed by the e-waste hoax, and people who made money off of it need to do more than just hope no one reads my blog and it all goes away.  Because as the piece in Al Jazeera by Jacopo Ottaviani shows, the truth comes out eventually.