Revenge of the Certification - SERI, E-Stewards Make Threats

As a former regulator, I know better than to let a regulated party "get my goat" and draw me into a pissing match. While I had the power of "you can't fight city hall", the regulated party merely has to create the "appearance of impropriety", not prove impropriety itself.

I've been glared at and - in the case of E-Stewards - directly threatened. "Stop saying bad stuff about us. I don't want to have to go after you." Promise, that was said.

Three Truths and a Lie at SERI - Is R2 Certification the Enemy of the Good?

Most followers of the Good Point Ideas Blog already know that the R2 (Responsible Recyclers) Certification program was developed over a decade ago by US EPA.  EPA's Clare Lindsey and Bob Tonetti hired a professional consensus mediator, John Lingelbach, to moderate the development of agreed upon standards that would achieve better results in reuse, repair and recycling of used electronics. Lingelbach later incorporated the Sustainable Electronics Recycling International organization to "house" the new standard. SERI realized that the original standard developed by EPA would be a public document, not copyrightable... so SERI tweaked the R2 Standard in order to establish a way to earn revenue.

SERI's R2 Standard gives prescriptions for electronics recycling practices.  The practices are developed by the Technical Advisory Committee (TAC, the ongoing advisor team from the industry). The TAC standards, if passed by the SERI Board of Directors, create new rules (red tape) for Certified Recyclers to follow.

Without even a formal change in the rules, SERI can issue guidance to reflect a change in interpretation of the original rules.  That's right, a TAC can act like a radical Supreme Court, with no tether to precedent. A clear example of this took place during this year's audit of Good Point Recycling, which passed 99% of the Audit with flying colors. However, the auditor called foul on a trade which passed R2 audits the previous 9 years... a trade that has taken place with the same downstream vendor for 17 years. A new "interpretation" of the old rules may cost my Vermont company $356,000 dollars per year, while achieving zero environmental benefit.

This is messed up. The rules have not yet been changed, but the "interpretation" of the old rules has.

10 Years Of Good Point Recycling Blogs: What's Been Learned?

Ten years ago, most of the mainstream press in Europe and the USA had accepted the cartoon thesis that if electronic waste is expensive to recycle, that shipments of used electronics to Asia, Africa and South America were to avoid those expenses. At least, 80% of the time.

We took that on here, before anyone else would touch the controversy with a 10 meter pole. Here's a retrospective on what was, and still is, relevant in the Good Point Recycling Blog.

When poor people are paying for something (including transportation), it is not "because" the rich are willing to ship it.

We demonstrated that with the "Big Secret Factories" and 60 Wasted Minutes blogs. The sea containers of CRT monitors headed for Asia were never, ever full of large CRT televisions, even though large CRT TVs had more copper and costed more to recycle. In fact, the purchase orders did even accept Sony Trinitron 17" desktop monitors or screen-burned desktop CRTs or pre-VGA.  When someone is paying you $10 each for something specific, and refusing to accept other similar CRTs even if you pay them, it probably has nothing to do with (ahem) "rice paddies".

Brad Collis [CC BY 2.0]

Real Time reporting on BAN Report - Dell Reconnect Fallacy

Click BELOW for Real Time Analysis Blog on Controversial NGO + MIT Allegations #trackingewaste.

- NGO False Claims Act Rebuttal
- Methodology / Fallacy in Sampling Data
- False Claims vs. Goodwill Industries, Dell ReConnect
- EStewards Accusations vs. Total Reclaim / Seattle
- Alternative Explanations for "conclusions" reached by NGO
- Research leads, links to vetted data.

Unlike normal blogs, this one is being updated with information about the "scandal" of alleged e-waste exports to Hong Kong and other countries, made to support NGO's claim that it's paid e-Stewards certification, or national legislation, would cure environmental problems overseas without resulting in collateral damage (impugning reuse and refurbishment operations, boycotting geeks of color, sacrificing tradeable commodities covered under WTO "cores" law, racial profiling of recycling operations, false attribution of Basel Convention standards Annex IX B1110, fallacy in sampling data, sampling bias, etc.).  The chief counterpoints to this blog (the story we are debating) can be found at the links below.

http://kcts9.org/programs/circuit

BAN Web page (just going online) http://www.ban.org/trash-transparency

MIT SenseAble City http://senseable.mit.edu/monitour

Like every one of these blogs, the views here are only my own and do not represent my company, any research or journalists I cooperate with, or the not-for-profit Fair Trade Recycling group (WR3A). The views are put forth in belief in debate, rebuttal, and defense of a trade which has received exaggerated and hyperbolized accusations, often against Emerging Market Tech Sector businesses who have little ability to respond to "profiles" created in the Western Press.

For ten years the Blog has told everyone that the NGO was making up the "80% Export" e-scrap myth out of whole cloth, and knew it was misleading reputable journalists in an "e-waste hoax" campaign that benefited the NGO financially.   For ten years we have documented that the NGO uses photos of poor people, implying it benefits them, but never spending a single penny to assist or aid them in any way.  For ten years this blog has alerted Interpol, EPA, trade associations, university researchers, interns, legislators and journalists of misleading and incomplete information being generated about the import and export of second-hand and secondary market commodities.

I do not know how long I will update this piece on the NGO's accusations against Goodwill Industries and certified and non-certified electronics recycling companies, and the overseas markets they may or may not trade with.  My passion for this is driven by victims in developing and emerging markets who are a) recycling material their own country traded in to them in upgrade, b) refurbishing newer second hand equipment imported from the USA and other "rich" nations, and c) general disgust as an environmentalist that organizations seeking to benefit from "strategic metals retention" or "planned obsolescence" or "protecting shredding investments" may be funding a propaganda campaign against the people I called (over ten years ago) "Geeks of Color".

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Fighting Over the Poor (instead of For them)

Watching Hans Rosling's latest presentation at Swedish statistical institute "GapMinder".

"Don't Panic - End Poverty"

It is a bit long and overlaps a lot with his TED Talks, if you have already seen them.  But if you have not, it's interesting how his trips to Malawi, South East Asia, etc. put poverty in a flesh and blood, rug on the floor of the mud hut, context.

He starts with his trademark audience quiz.  This time it's not multiple choice, and only 3 questions.

1. How many people (out of 10) have electricity?

The audience answers average around 40% of people in the world have electricity, which was the rate in 1960.  The actual rate with electricity today is over 80% (I have read it's 87, but he rounds to 8).

2. How many children (out of 10) are vaccinated against measles? 

Highest audience response was 3 (followed by 1, 2 and 4).  The right answer, 83% of the world's children are vaccinated.

3. How many girls (out of 10) go to primary school?

Most of the audience answers range from 3-6.  But it's 90%.

Rosling is facing the same challenge that used electronics traders face in addressing "#ewaste policy".
Simple. The Press reports "if it bleeds, it leads".  Consumers buy bad news.  And one of the biggest concerns those of us working with Agbogbloshie face is that if the "Ewaste Scare" is a hoax, does Agbogbloshie just fall off the map?  Is there a way to harness these western eyeballs to achieve something good for the people who live in or near the slums of Old Fadama?

Rosling is doing a good job of correcting the exaggerated perceptions, but seems to also struggle with the temptation, therefore, to shrug.   So he emphasizes this time that while 12% extreme poverty is an amazing improvement over the past 3 decades, that it still represents a BILLION people.

How would Rosling react if he was in the audience, and the leader of an NGO was on stage, telling everyone the exact opposite of the truth, that things are getting "worse"?  How would he feel if an NGO called him a "poverty denier", comparing him to climate change skeptics?

Fortunately, the discourse over economic statistics is more civil than in the Waste business, where stock in defamation lawsuits is rising faster than scrap metal and plastic prices.

Open Minded Electronics Importer Gets R2 Shaft: CEFAD

There are way too many trolls on the internet.  People who are either super sure of themselves, or who get off somehow by acting that way, appear to go out of their way to shock and provoke insult.

trolling e-waste downstream markets

There are also too many wishy-washy agreeable people, people who 'like' whatever is being said today by the people they are near, most comfortable with repeating second hand impressions as fact.

And then there are really principled people, who really think they are good and fair, who really mean to do well, but they are caught in a tide of group-think.

Some of us cannot even see how our perceptions of reality have been caught in a kind of cultural gravity that general impressions cannot escape.   Many of these people are even agents of conscience, trying to make the earth a better place, as best as they know how.

It was someone like the latter to whom I sent the email (bottom, in yellow) for someone's first R2 (Responsible Recycler) end market report two years ago.  I have changed names, hotlinks, and email addresses, otherwise this is exactly what we sent.  This is a real case of "collateral damage"... no one meant to do anything but good...

Someone I wrote about in September 2012 is now out of business.

Basel Action Network Accuses R2 Certified Companies of Illegal Acts

On June 17, Basel Action Network released another attack piece, accusing R2 Solutions of violating international law.  In doing so, BAN has indirectly attacked my company, which chose to pay for R2 Certification rather than accepting E-Stewards written offer to pay BAN to certify our operation to their own E-Stewards Standard.

Here's an "as concise" critique of BAN's "concise critique", based on the following international law.

Article 17 of the United Nations International Covenant on Civil and Political Rights states: 

1. No one shall be subjected to arbitrary or unlawful interference with his privacy, family, home or correspondence, nor to unlawful attacks on his honour and reputation. 2. Everyone has the right to the protection of the law against such interference or attacks.

Five Fundamental Flaws.   A Concise Critique of the R2:2013 Standard  / June 17, 2013

"The [R2] Standard suffers greatly from its seeming intentional avoidance of international law as it refuses to acknowledge or recognize the definitions and obligations, decisions and guidelines of the Basel Convention, which all developed countries, except the United States have ratified and implemented and is now globally adopted by 180 countries." - Jim Puckett

There are three problems with BAN's analysis of their competitors at R2 Solutions.  The third is the most important.

Corrective and Preventative Action (CAPA)

Our company just went into an environmental "Surveillance Audit" for R2.  Some advice for people who are getting certified, or thinking about getting certified...

The temptation is to think that on the second audit, you've done this before.  You got the initial certification, you think that's the hard part.  No.   Joining the Army is the easy part.  Staying in the Army is the hard part.

When you think about it, there aren't too many economic incentives to keep someone out of a certification, whether it's E-Stewards, or R2, or ISO, etc.  What the company is signing up for is a process.  It's like joining a church, it's not about your past sins, it's about your commitment to being better.

What happened prior to our Surveillance Audit was that I took two trips to the Southwest (things are heating up at Retroworks de Mexico, despite the snow down there) and left people I trust in charge.  They have earned my confidence, as in confidence to do what I've trained everyone is our culture to do.

Efficiency, Good Work, Value, Accountability.  Get 'Er Done, combined with Know-How.

In that vein, everybody at the plant was motivated, without me telling them so, to make the place ship-shape.  We were proud of our company, and open to the audit with open arms.  A special clean up crew was assigned room by room to make sure everything was swept up and ship shape.

Well, we do "batch work" a few times a year.   Like we let the projection tubes build up until there will be enough of them to actually fill barrels with ethyl glycol.  If you do them as they come in, a few per day, you tie up more floor space with 1/8 full barrels which are actually more susceptible to spills than the projection tubes they were stored in.  So it makes sense, operationally, to store up 30 gaylords of the projection tubes when things are busy in the summer, and to keep people employed in the winter by draining them in a batch.

LCDs are similar.  In the first batch, you test working.  In the second batch, of the ones not working, you examine for capacitors and other "easily" repairable problems (for those in the know).  In the third batch, you leave for last the de-manufacturing of the busted-up-beyond-hope LCDs that need demanufacturing.

You are proud of the quality of your reuse.  We are led to believe, and it's true, that a lot of companies will sell the LCDs "as is" in a mixed lot.  Economically, you can "externalize" the cost of the LCD demanufacturing if you use the reuse value of the working and repairable to make the other LCDs tag along, as "toxics along for the ride".   So we haven't been doing that, we are proud to be tackling the hardest part of the work during the R2 winter surveillance audit.

So you've got a couple of people doing something new, something they aren't as experienced in, in the "batch work".  And you have a crew of eager clean up guys, circling around, trying to make the place look neat and orderly before the auditor arrives.

Crack.

That was the thin ice.

TIME OUT: Free the Geeks! Release E-Stewards Rules!

In reviewing Parts 2 and 3 of the essay "Environmental Malpractice", I'm a bit stumped... because I don't know what the "Practice" E-Stewards requires actually IS.

E-Stewards markets itself as being superior to R2.  But R2, the Responsible Recycling standard developed by environmental organizations and EPA, is PUBLIC.  They have their document up for 2013 compliance changes, and are soliciting comments this month.

There is no similar public comment period for the E-Stewards Standards, and in fact you have to pay them money to see the rules, and agree not to republish them.   "Licensing" the path to goodness, it's a remarkable cause.  It's kinda now, kinda wow, kinda 1400 AD.  Just which "Madonna" are we talking about?

If there is a way to heaven, and you demand donations to tell the secrets that will free me from hell, just how noble is your cause?

FREE THE GEEKS!!!!!!!!!!

UPDATE:  Following this publication, we received news that Joseph Benson settled his case, after 3 years defending himself in court, for 11,000 British pounds.  http://www.independent.co.uk/news/uk/crime/owners-and-employees-of-a-string-of-waste-disposal-companies-fined-over-200000-for-exporting-dumped-electronics-to-the-developing-world-8386688.html

The Basel Convention: Bayesian Soup Nazi Episode

Ok, Another E-Scrap Conference, and another allusion to an American comedy.  I hope my international readers will be patient.

R2 or E-Steward?  Who has the best recipe?

Yesterday's E-Scrap 2012 Conference in Dallas had two sessions worth writing about.   John Lingelbach of R2 and Jim Puckett presented on the two certification programs for Electronics Recyclers (along with auditor Kelley Keough of Greeneye).   Later, Travis Reed Miller of MIT presented on the use of Bayesian predictors to refine data, and Laura Bloodgood of US International Trade Office reported (without data) on the survey work on 900+ e-scrap firms.

The session with BAN E-Stewards and R2 was very amicable.  Sitting in the audience, I couldn't help but feel bad for having taken Puckett tiredly to task the day before in the blog.  They seemed to narrow the "disagreement" between the two programs down as follows:

1. E-Stewards is expensive.  And R2, while cheaper, is unsustainable (it needs to be more expensive).
2. BAN - a little unclearly, I thought - described their belief in evolving WITH a Basel Convention group.  The Basel Ban Amendment - not passed - should be incorporated in the standard because they are confident it will be passed.  The E-Steward position on export of goods for repair, while CLEARLY on the list of Annex IX "non-waste" activities, is that they should be held to a standard of a recent committee at Basel Meetings... ie not to International Law, but held to the amendment of the international law which the non-profit NGO promotes for a living).

This "adherence to promoted future law" of course is what frightens the USA away from Ratifying Basel Convention.   The USA Congress might agree with everything in a convention as written, and then Jim Puckett may make a presentation in Jakarta or Columbia, and the non-elected international group of attendees may vote that repair, allowed in the Convention, should no longer be allowed.  In that case the USA has passed a law which gives a non-elected international  interest group, effectively, regulatory power over USA companies.  UN Treaty 101.

Does the Sun Orbit Our Compassion?

Guiyu, China is a polluted place.  Part of it is polluted by the textile industry.  But these burn-houses for circuit boards are real, and no one is saying they are good.  Not much "e-waste" recycling is done by the river, there is no CRT business in Guiyu, and the sophistication of the chip sorting and reuse business really deserves more credit.   But there is pollution there, enough pollution for children to have high levels of lead in their blood samples.  Without question, we can see it.  Guiyu deserves our help.

My fair trade recycling campaign is not about making excuses for the sale of circuit boards to places like Guiyu.  What we propose is that trade can be used as a lever to incentivize reforms.   Just as we lowered the price of SKD monitors sold to Malaysia in return for ISO14001 certification and glass-to-glass recycling of residuals, we believe that Guiyu's economics can be used to negotiate improvements to the standards for children.  This is a math problem.

My African Neighbors, 1985

Agbogbloshie, Ghana is really the same story.   There's no denying that its sad to see a kid busting a CRT tube with a rock.  I'm not sure why someone does that... there's not much inside a CRT tube but a metal shadow mask.  But I've seen it on film, and even if the TV was  used in Ghana for years, I'm not heartless.  Lead in children's blood bothers me a lot.

My fair trade recycling campaign is not intended to make excuses to send "toxics along for the ride" to Ghana or Nigeria.   It's intended to reform the trade, so that people keep their jobs, their repair jobs, their reuse jobs - even their recycling jobs, if we eliminate the burning. But most of all, it's about observing the constellation of the recycling trade more closely, listening, doing Q-sort, and not selling the conclusion that the sun orbits the earth.

Two More Controversial Electronics Recycling Practices, Part 2

If we examine the practices for LCDs which require repair or disassembly, on line, we find two things:

1. Importance of using a "certified recycler"
2. Toxic properties in the LCD CCFL (cold cathode fluorescent lamps contain minute amounts of highly toxic mercury phosphors)

However, you find next to nothing about what "process" is actually being "certified" to occur.   Shredding?  Retort?  Safe handling?  Packaging?   Lots of "white man ju-ju words" and very few VERBS.

• Fair Trade Recycling Intern Adelaide Rivereau has written about the step-by-step process that happens in MY company.
• IFIXIT.org has a number of tear-downs
• REPAIRFAQ.org has some good descriptions of LCD repair from the older models likely to be turned in to an "e-waste" program
• Digitimes, the Taiwanese high-tech display industry periodical, remains the rosetta stone of understanding the display market 

What should an "e-waste" recycler know about LCD lamp recycling, and when should s/he know it? Time for an "environmentalist actuary" to follow the goods downstream, into the domestic and export recycling markets, to tease out the risks, harms, rewards and benefits.


- Handle with care
- Stop the "zero landfill" practices for CCFL

Two More Controversial Electronics Recycling Practices

Greenpeace video - But Don't finger them

The ten worst "e-waste" recycling practices in Africa (March 5) is the highest read post of the year.  The pan-African Conference on WEEE in March (WR3A sent 3 representatives) generated a lot of interest in fair trade recycling.

Africans have inherited piles of junk electronics from decades of use (places like Lagos and Yaounde have had television since I lived there in the 1980s).   The "stuff" at Agbogbloshie was in use for years, traded in from residents in cities like Accra and Lagos for something "gently used" off the boat from Europe.


Still, the challenge of "Fair Trade Recycing" is to make recycling exports better, and to address export problems as soon as we see them.. We have to add two more environmental practices to the discussion of "exporting harm".




- mercury lamp recycling from the backplates of LCD screens
- electronics plastic recycling

The problem is, while the pollution from these activities occurs in Africa, South America, and China, it comes from our best recyclers... from R2 and E-Stewards alike.  At least with plastic recycling, there is no debate.  No one claims not to export scrap plastic, and no one has shown up close what that market looks like.

mercury CCFL

For that reason, this will not be a popular thing to write about... The issue must be handled with care.  When "E" stands for "Epic Fail", we don't want to feed the anti-environmentalist, climate-denying, trolls.

But it's better when we as environmentalists get out in front of the problem, rather than wait for a journalist to write a gotcha-man-bit-dog anti-recycling story.  My theme is that we have more confidence in professions, like medicine, which announce on their own that a treatment may do more harm than good, because they have research universities studying human health on a long term basis.

Tomorrow, Part 2:  Mercury lamp recycling from LCDs.

Just a peek at the good news - in LCD lamp recycling, and in plastic recycling, the more it is done by hand, the better the outcome.  If you are studying for your E-Waste Recycling S.A.T.,  "shredding machines are to lamp and plastic recycling as RoboCop nemesis Ed 209 is to stairs..."

Put Yourself In the World's Shoes

I got some positive feedback on the slide I put up two days ago (from my "Fair Trade Recycling" presentation, which has been given at CES and Colleges in 3 countries during the past 6 months).

Here are a couple of other slides from the same presentation.

The first shows the relative size of the market for computer displays.  People earning $3K-12K per year are getting online at 10 times the rate of growth of wealthy nations since 2001.  But the "boycott the poor" advocates shows pictures of primitive dumpsites to describe 6 billion people.

And even the poorest of the poor deserve a bit of a break.  Recycling isn't THAT bad a job for the very poorest people in the world.  If we control the three worst practices - burning wire (little of which comes from computers anyway, that will not be affected by the HR2284 boycott), dumping broken CRTs, and aqua regia acid baths for circuit boards (another rarity), then recycling stacks up pretty well with other choices - like sex worker, miner, Somali pirate, child soldier, etc.

The term "parasites of the poor" and "accidental racist" are a little tough.  But the longer this stupid idea of boycotting poor people and shredding metals into smaller un-fixable pieces goes on (without any intelligent comment or response to people like me), the louder I have to get.

Good Point Recycling is R2 Certified!

[ May 2012, Middlebury, Vermont ]

John, Colin, Pete and Rachael did what was necessary to get our company R2 Certified.  We received our Certificate this week, and it has been registered with R2 Solutions and ANAB.

Who gets the credit?  Not me, that's for sure.  I was travelling to Mexico and South America and Vegas and DC during the past quarter, and sending staff to Nairobi, and negotiating Fair Trade Recycling contracts in Europe and Asia.  While I was off making it more difficult to certify and mass-balance more and more activity, the staff at Good Point Recycling was busy making sure the factory runs, orders are met, material is safely processed, and we do things right.  John and Colin did everything right, and Rachael and Pete made sure the state contract and our clients didn't suffer or stray from the rules John and Colin set.

Me, I just made the job harder.  It's easy to get certified if you refuse console televisions and just take off lease computers and laptops ("no hair on the meat", my pal Joe says).   It's easy if you aren't dealing with 12 countries, and 8 different purchase orders, with different reuse specifications.

Want to get R2 Certified the Easy Way?  Lay off the staff, stop the reuse and exports, don't handle residential material, and buy a shredding machine.  Better yet, don't do it in house - collect the material and send it to someone else's shredder.  The less your company tries to do, the less you must document.

It's easier to get Environmental Health and Safety (EHS) communication if you aren't cross-training women from Mexico, or running a job training program for challenged and disabled people with the local counseling service.  It's easier to certify a few things, than to be a "general practitioner".

Why All Good Recyclers are Exporters.

There are many good recyclers, and we are all exporters. 
The purpose of certification is to "out" the liars, not to debate the outliers. 


During the past week (blogs below), I've written several essays concerning marketing themes which are "attacking the category".

Negative campaigning, also known more colloquially as "mudslinging", is trying to win an advantage by referring to negative aspects of an opponent or of a policy rather than emphasizing one's own positive attributes or preferred policies. In the broadest sense, the term covers any rhetoric in which one refers to one's opponent in an ad hominem manner. [ wikipedia 2012.02.08]

Negative imagery of competitors' export practices probably accounts for "80% of advertising" for ewaste recyclers (a statistic I just manufactured... see how easy it is for Americans to make things - up?)

Export policy is important, it does matter.  Below are five distinct export categories, and the niches they serve.   How we manage and certify the first four will help us all to control the 5th (see post "Ewaste Travel in Scrap Metal" 2010).   Mixing CRT glass and mercury bulbs into bales of scrap metal is one dumping problem, but ship captains stranded with cargo refused at port is another cause of the same "export for dumping" problem.   Basically, there are five ways for your "e-waste" to get from Here to There.

FIVE CATEGORIES OF E-WASTE EXPORTS

1.  Export No Intact Unit Category:   Some of us feel safer exporting raw materials only, and market the "no intact unit" standard as an option.  These companies attract business from OEMs concerned with reuse (market cannabalization), counterfeiting, or the "grey markets" somewhere in between.  It's a legitimate recycling category.  These companies represent an excellent choice, for example, for an OEM with faulty parts taken back under warranty that they don't want redistributed.  These recyclers export bales of steel, plastic, copper, aluminum, and circuit boards, sold openly on the commodities market.  (slideshow of China's metal recycling companies, which buy shredded material for hand sorting - The Atlantic Monthly 2008)

2.  Export of Tested Working Category:   Some of us sell to retail markets, such as schools or direct retail shops, which are not in the repair business and are willing to pay more for something "fully functional" and "tested working".  The recyclers who sell to the direct-reuse market tend to wipe hard drives, reinstall MAR licenses, and do other things to ensure their exports are what the buyer ordered.  (Slideshow of Egyptian repair / direct reuse markets, 2008)

3.  Export for Repair and Refurbishing Category:   Within the remote corners (83% of the world), there are mind-blowing repair and remanufacturing companies.  Some of these began as contract manufacturers (e.g. CRT factories) and performed warranty repairs as well as assembly.  Some have turned to full-fledge cores refurbishers, creating thousands of jobs in emerging markets, taking back things like old CRT tubes or smallish LCDs and recutting and re-vamping them.  They make things like monitor-television-DVD combos, which are sold in vast quantities to people earning $3,000 per year, who cannot afford to buy all 3 separately.  They tend to be very picky, but not about things like 120 volt power supplies... whether the power supply works or not, it's getting replaced for sale in a 220 volt country.  It's a very legitimate category.  The fact they buy non-working power supplies as well as working power supplies is evidence that they are the opposite of primitive.  Slides of the factories I've visited are available here.

Redemtech Explains (Attacks) R2

Singapore Internet Cafe

Basel Action Network says that my criticism has been mean-spirited, sometimes "ad hominem" attacks.  My friends see this blog as a purely defensive force.  If BAN and E-Stewards stops with the attacks on refurbishers, a la California Compromise, we could do great things together.  But classifying all 83% of the world in "non-OECD" nations as primitive wire burning victims is just wrong.


Here's a case in point.  E-Stewards are mounting their own blogs.  Here is one, sponsored by Redemtech of Ohio, by professional writer Carol Baroudi.  I'm not attacking Redemtech here.   But using Carol's own words, by agreeing with them, are we attacking her? Or is this a ricochet wound?


Redemtech is an electronics recycling company in Ohio.  They are an E-Steward certified "ewaste" company.   Bob Houghton, the CEO, has been in the business for a long time, and is a respected IT recycler.  This is not an attack on Redemtech... but this is the only way to reply.  When Redemtech started a blog, I left some comments.  I don't recall the comments ever being approved by moderators.  So, I'll try to get my point across here.

Redemtech blogger Carol Baroudi sounds off on R2, EPA's "Responsible Recycler" certification, and why E-Stewards is superior.   Note the tone...

First and foremost – No non-functioning equipment is ever exported. Got that? Never. R2 makes no such claim.

Got it.

This is certainly true.  I don't think anyone disputes that.  What is disputed is whether an E-Steward's working P2s are somehow superior to the P4's with replaceable capacitors which Wistron or another Asian subcontractor wants to buy.    Or whether the USA creates more jobs shredding those P4s rather than selling them back to the company that makes capacitors, for 5 times more money.  What is disputed is whether the same factory that takes back product for repair under warranty can also buy the exact same computer at surplus and do the same thing.  E-Stewards, according to the quote, considers warranty repair and manufacturer-takeback to be a crime.

There are more examples of "non-functioning" but good exports.  Empty ink cartridges for refilling ... no one claims those are "functioning"... there are lots of things in the "cores" business, for which "fully functional" is not an important criterion.   And it's all legal under Basel Convention Annex IX.  Lots of OEMs want us to shred the ink cartridges, rather than refill them, because they sell new ones for $20-30 each.  Maybe that's why some OEMs are the biggest contributors to E-Stewards.

Redemtech shipment

CRT monitors.  Why is "non-functional" so important to Carol, when it's not what the buyers are screening out?  I have personally seen Redemtech containers being unloaded in Jahor Bahru, Malaysia, when I went to visit a buyer there.   The Redemtech CRTs may well have been "tested working".   But the buyer's specifications were not "tested working".  The buyer didn't want "working" R4 tubes (trinitron).  But the buyer would be happy to receive other tubes that did not have a working power supply, because that's what the buyer does - refurbishes tubes.

These Redemtech PCs are being reused, and Redemtech should be as proud of trading with the Malaysians in this photo as I am.  If they refuse a tested working 21" tube because it's too big, or a 17" because of a surplus backlog or raster test, and pay $10 for the others... how could they be burning them?  It's obvious without visiting them.  But I did visit them, and was impressed.

I am the one who raised "warranty repair" as an issue, thinking that might cause people to think a little bit about who the contract manufacturers were.   I worked with ones which did both warranty returns and purchased refurbish-able ones on their own.

I thought that might really bring people closer together, explaining how warranty repair is the same factory as purchase certain (but not all) "non-functioning equipment".

But it's true.  First and foremost, warranty returns are non-functioning equipment.   They are made almost universally in factories which are not OECD.  Redemtech asks if we "got that"?

Got it.

When my company ships to the factory, we read the specifications in the PO, we remove what they want us to remove (including working equipment which is in surplus, or low demand, or wrong size/spec), and we get a feedback or QA/QC report explaining exactly how well our staff prepared what they shipped, and whether any of it was outside what they needed.  We had the factory inspected to meet R2 processes, and as a result of our contract, they became a CRT glass processor, taking back bad ones from the places they sold good ones (think needle exchage or "computers for clunkers").

So my problem with E-Stewards?  I think we can agree:

First and foremost – No non-functioning equipment is ever exported. Got that? Never. R2 makes no such claim.

So I haven't said or implied Redemptech is a bad company.  I think they are a great company.  I just happen to think that the people we both sold to in Malaysia had a great company, too.  And from in depth, face to face meetings, I am pretty sure I know what they need from us to make the world better.

What I don't understand is what the heck the factories Redemtech and I both sold to have to do with the primitive child photos in burning ditches which E-Stewards displays on its website.  Mr. Ong said "hi", by the way, when he gave me a ride across the bridge to his home in Singapore.

Boycott E-Stewards Recyclers?

Here's an excerpt from the latest press release from Basel Action Network, which has announced that R2 (Responsible Recycler Certification) is accepted by E-Stewards, but not sufficient:

"BAN created the e-Stewards Standard after the R2 Standard failed to prohibit exports of hazardous electronic waste to developing countries"

Jim Puckett, BAN, sells E-Steward Certification, 

receives % of gross from E-Steward Companies

"After the R2 Standard FAILED"?  E-Stewards rolled out before R2 ever went to press.  R2 has not even been accused of anything specific except not being the choice of BAN, a choice BAN made before R2 went to print.   Now even "not being the choice of BAN" is in question, as BAN's announcement was that it was adapting R2 standards...

In any case, the studies have been released... even non-certified exports to Africa were 85% reused.  Just how bad could R2 certification be?

For 10 years, the non-profit NGO BAN said that 80% of the goods exported to Africa were e-waste burned in terrible conditions... the conditions prior to either R2 or E-Stewards Standards.  They showed us pictures of the kids in the dump, working on "allegedly" imported computer junk.  They said that the contract refurbishing (white box re-manufacturing) factories were "poisoning people" and "illegal"...

Now, seems it ain't so.

Responsible Recycler's R2 Pledge Haiku

We need an audit
To prove we don't dump e-waste   

Recycle fairly.

Ultimately, the test of whether E-Stewards or R2 Certified Recyclers is the right guarantee will not depend on photos of children burning waste.  It will not depend a company's unwillingness to pay huge fees to a political group which defames the best and brightest nerds in the business.

ethical ewaste 

my dirty little secret
we traded with geeks.

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.