How E-Stewards Testing (required for reuse in Vermont) is an unfair standard of comparison
In the next 60 days, my company will have to propose a standard to be allowed to reuse electronic equipment which we purchase from other states and bring into Vermont for double-inspection and resale overseas. Those re-exports have brought millions of dollars into Addison County Vermont, and have created local jobs. We were made the exclusive supplier for used computers by some overseas companies, and used that leverage to give incentives to get them to establish proper recycling infrastructure. In a word, of the millions we brought into Middlebury, we are proud of the millions we rebated the overseas companies who became ISO14001 and ISO9000 certified, who established proper recycling methods for the "hazardous fraction" which they could not repair and resell (or chose to electively upgrade when working).
Vermont ANR promulgated E-Stewards "testing procedures" into law, because they "sounded" stricter than our procedures. Here's my problem - we provided data on all our reuse, resale, and proper recycling. The mythical standard we are being compared to provides no such data.
Vermont ANR could have saved us a great deal of stress if they had put the Procedures as a condition of managing Vermont Covered Electronic Devices (requiring it under the RFP), or given us a year to propose alternatives. Instead, Vermont ANR made the Procedures cover NY, MA, RI, NH etc., effective very shortly, regardless of our contracts out of state. No competitor out of state will be bound by these procedures for the material we buy in MA, RI, NY, NH, etc.
In the next 60 days, my company will have to propose a standard to be allowed to reuse electronic equipment which we purchase from other states and bring into Vermont for double-inspection and resale overseas. Those re-exports have brought millions of dollars into Addison County Vermont, and have created local jobs. We were made the exclusive supplier for used computers by some overseas companies, and used that leverage to give incentives to get them to establish proper recycling infrastructure. In a word, of the millions we brought into Middlebury, we are proud of the millions we rebated the overseas companies who became ISO14001 and ISO9000 certified, who established proper recycling methods for the "hazardous fraction" which they could not repair and resell (or chose to electively upgrade when working).Vermont ANR promulgated E-Stewards "testing procedures" into law, because they "sounded" stricter than our procedures. Here's my problem - we provided data on all our reuse, resale, and proper recycling. The mythical standard we are being compared to provides no such data.
Vermont ANR could have saved us a great deal of stress if they had put the Procedures as a condition of managing Vermont Covered Electronic Devices (requiring it under the RFP), or given us a year to propose alternatives. Instead, Vermont ANR made the Procedures cover NY, MA, RI, NH etc., effective very shortly, regardless of our contracts out of state. No competitor out of state will be bound by these procedures for the material we buy in MA, RI, NY, NH, etc.
In apparent fairness, ANR has allowed us to submit "alternative procedures" which are at least as effective as their Procedures. However, ANR's standard bearer (VPIRG) provides absolutely no data for us to compare our process to.
