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.

Certification and Racketeering 5: Analysis of Seven GPS Tracking Studies

2018 GreenTrack Report found only 5% export, including export to OECD countries grntrac.com DWE

In the next blogs of this series "Certification and Racketeering", we look at a chart comparing 6 actual and 1 hypothetical use of GPS Tracking Devices to follow largely unwitting and unwilling subjects.  We compare methods of placement, tracking, and financial involvement of lead investigators. From there, we will delve into whether the study acts as "Environmental Watchdog" or merely protects the claims of being an authority when those claims are threatened. If, for example, a GPS tracking study specifically seeks to discredit or scandalize someone who has a beef with the Investigator, does that influence the mechanics of the study?

In the 7th hypothetical GPS Tracking study, I've deliberately created a clearcut "Racketeering" use (using the tracking study to offer a solution to a problem that would not otherwise exist without the financial interest of the investigator). The hypothetical would clearly be a matter for the American Civil Liberties Union, or EFF, or Interpol or Bob Mueller to decide. We then correlate the studies to see which ones have more in common with the Racketeering Hypothesis.  Then we look at quotes and behavior of the lead investigator.

Certain MIT students, when they get older, may want to come forward and disclose specific methods used to drop specific devices at specific places. I can promise anonymity and cover your costs. I can also put you in touch with MIT's own attorney, who took over correspondence after MIT Senseable City Lab excused themselves from further collaboration with BAN.org

Fair Trade Recycling Geek in Tamale, Ghana

Later, we will visit ("Take Your Pic") the use of cringy photos to jolt emotions when the actual statistical findings are not doing the trick. The art of a deal "selling" an unnecessary service, deceitful or otherwise, involves provocative / race-baiting imagery.

In the DWE tracking study, Dennis Ward    @dward_dennis gives us charts. In report by BAN, we have constant tear-jerking imagery evocative of our worst fears and perceptions of their so-called "Third World". But let's first focus on the methodology in 7 separate GPS Tracking Reports.

GPS trackers show exchange of products between two consenting parties.  There is not a single case of direct dumping of used electronics at foreign landfills. Who are we guilty of doing business with? And what makes our partnership suspicious?

Racketeering and Certification 4: "Framing" the Export Market

In the first blog in this series on Racketeering and Certification, we looked at actual problems in Africa (assassination of a journalist who reported on Racketeering). We then looked at the monetization of a so-called "charity" which claims to similarly expose problems -- for cash.  Pay for #EarthEye / "EarthEye"  and they will track your competitors, Pay for E-Steward Certification and get advance information about the same trackers. We looked at the charity's practice of sabotaging used devices (creating a problem) in order to gin up sales from paying clients (including commission-based profits, normally disqualifying for 501-c(3) "charities").

In part 4, let's look closer how this tracking works.  Do Basel Action Network's services cross the line from "watchdog" and become simple extortion, or racketeering? Is the problem they purport to solve one of their own making?

Jim Puckett "Frames" Africa

If a single computer monitor from this African Tech Sector shop went to Agbogbloshie days after Jim Puckett photographed it, we will bet it is the very one that Jim sabotaged. How more cringy can this "charity" get while "framing" the story?

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.

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.

BREAKING NEWS: E-Stewards Recognizes Mexico!

AND NOW (DRUMROLL) THE "e-WASTE" STATISTIC IS "OFTEN"!!!!

Personalize funny videos and birthday eCards at JibJab!

READ BAN.ORG'S PRESS RELEASE FROM THIS MORNING (HIGHLIGHTS IN RED)

Mexican Electronics Recycler, Achieves the "Gold Standard"

Grupo Ecologico MAC become e-Stewards Certified

Seattle, Washington. November 28, 2012 – The Basel Action Network ( BAN ), a global toxic trade watchdog organization, announced today thatMexico-based Grupo Ecologico MAC ( GEMAC ) has become a certified e-Stewards® recycler. GEMAC boasts 20 years of experience in the recycling industry. Its facility in Guadalajara, Jalisco, Mexico has received the e-Stewards certification, and an additional facility in the state of Querétaro is on track to be certified soon. GEMAC offers electronic and appliance recycling, IT asset management, metal processing, refurbishment, shredding, and data wiping. It caters to electronic equipment manufacturers, retailers, public institutions, private agencies, and government agencies. GEMAC offers world-class service to its customers and suppliers, providing the best management of industrial and electronic waste. It renders its services through a quality integrated management system, with focus on environmental conservation and health and safety of its employees.

GEMAC intends to also become ISO 9001 Certified in 2013, to complement its current ISO 14001, OHSAS18001, R2/RIOS, and now e-Stewards Certification.

“We are a responsible recycler in this region, and it is our priority to meet or exceed the highest standards in the industry,” said Jorge Macias, CEO of GEMAC. “e-Stewards Certification is an important and necessary step because it represents our company's philosophy and vision. These certifications reflect our commitment to proper management of commodities, which ultimately assures our customers that we operate our company with integrity and concern for citizens, our employees and the environment.”

Hazardous e-waste unfortunately is all too often not recycled by so-called“recyclers” but rather is shipped to developing countries that lack the capacity to regulate these imports or to appropriately handle the toxic e-waste. The e-Stewards Standard not only prevents exportation to developing countries and assures compliance with international law in this regard, but also ensures that the toxic e-waste is not dumped in landfills or incinerators.  Further, the standard safeguards against release of private data on computers or wireless devices.

“Companies like Grupo Ecologico MAC should be applauded as they have joined the ranks of true electronics recyclers that have achieved the highest marks for social and environmental sustainability,” said Jim Puckett, BAN's Executive Director. “Leaders lead, and GEMAC is leading Mexico to truly sustainable solutions.”

Now, all in good fun.  I applaud BAN bringing a Mexican company under the tent.  I hope they will go on and certify companies in Singapore, Malaysia, Indonesia, Egypt... the ones I've been sharing stories with.  

But why is it Seattle's "Gold" Standard?  Ka-ching.  At Fair Trade Recycling, the money goes from north to south.  To "earn" E-Stewards, Retroworks de Mexico would have to pay money north... to Seattle.

GEMAC is great.  They are in Guadelajara, a big university city, which is where we have recruited some great staff for Retroworks de Mexico.  Our plant in the cruel desert and mining area of Sonora, by contrast, is still struggling.

And let's recognize BAN for an important breakthrough, too.  No, not "recognizing" terrific programs like GEMACs...

WE NOW HAVE THE COMPLETE RETREAT FROM "80-90%".  BAN IS NO LONGER EVEN CLAIMING "UP TO".   NOW THEY ARE WAGING A WAR AGAINST "ALL TOO OFTEN".  I told you "80%" was a lie.  They never defended it, they just parsed the words away.  Recognizing good companies in countries with low per capita incomes is progress, just as abandoning false numbers is progress.

But... This is, after all, Still Sparta...

I would praise BAN rather than mock them, except for one thing.   Mocking them (or Intercon suing them, perhaps) seems to be the only thing that produces this kind of progress.  Would E-Stewards be in Mexico if not for Fair Trade Recycling's defense of Retroworks de Mexico and others?

Some will call this immature.  But Hurricane Joseph Benson of Nigeria, Hurricane PT Imtech of Indonesia, and Hurricane Medi-com of Egypt remain the Hurricane Katrinas of this "anti-export" campaign.  And I mean "Hurricane" in the sense of the Bob Dylan ballad.

I look forward to BAN and E-Stewards making more concrete steps to work with Geeks of Other Tongues.  The more companies they work with in Mexico, the more they will have to continue to moderate their use of "poverty porn".   And maybe we'll be friends one day.  Meanwhile, a job applicant at my plant yesterday brought up what they read about me personally in Slaparoo and in the Chicago Patch article...  So like the Lovings of Loving Vs. Virginia, the only thing I can do is kiss my partners overseas right on the lips in front of the cameras... not because I want to be in the papers, but because I must show I'm not ashamed of companies I work with, and not demanding they pay me money in order to announce they are "ok" to work with, like GEMAC pays E-Stewards.  

Rubin "Hurricane" Carter

We run a good plant in Mexico too.  We don't try to advance it by insulting or denigrating competitors (like GEMAC).

But we don't pay a percentage of earnings to the jokers in Seattle, either.

THE MONEY GOES TO THE PEOPLE IN MEXICO.

We didn't pick this fight, but...

WE WON'T BE E-STEWARDS PUPPETS!!!!!

Joseph Benson does not deserve to be in jail.  And if we paid e-Stewards the licensing fees for Retroworks de Mexico, we'd be financing the media campaign which put him there, and tore down good sustainable operations in Indonesia and Egypt as well.

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.

BAN Farewell: It's About Giving them Cash

The NGO Basel Action Network just announced they want to cash out on their "Stewardship" program.  This is what I predicted.  When they started, I said they are going to have to come face to face with real recyclers making real decisions, real uncertainty, and they would be FORCED to confront their pollyana unicorn-promise responses.  They just announced a retirement plan.  Submit your proposals to see them off.

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.

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.

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.

R2 Responsible Recycler Certification Vs. E-Stewards Certification: Synopsis

What is the difference between Responsible Recycler (R2) and E-Steward Certification?


There are already several posts this year about the technical aspects of the Basel Convention, EPA Export Rules, and differences in perspectives on "fully functional", "tested working", and "elective upgrade" of used computers and components.  A list with links follows below/bottom.


I've been involved with "legalese" since my days as a regulator.  When is a product "discarded"?  What is "original intended use"?  Does Basel Convention Annex IX allow an overseas buyer to "electively upgrade" (replace and improve parts) and refurbish?  What is "major reassembly"?


Dialogue with the groups opposed to international trade was rational and factual during the R2 Stakeholder meetings, and so continued when BAN.org organized a competing "E-Stewards" Certification program.  However, when BAN's marketing of that campaign, and of their views about the contract manufacturing or SKD facilities, turned negative, I became negative as well.  I hoped R2 Solutions and ISRI would continue the level headed dialogue with the protest organizations, and from time to time I could use the blog to express the opinions of "geeks of color", which was increasingly disgusted with the way Watchdog groups equated their elective upgrades with "primitive wire burning".

The central difference between E-Stewards and R2 comes down to this:  In non-OECD nations (China, Singapore, Taiwan, Malaysia, etc.), can a material be legally recycled if no toxic constituents are released per Annex III? Who answers that question? The ayatollah of e-waste, or the competent authority (EPA)?    

For example, can a computer refurbisher in Singapore send upgraded circuit boards to Japan for refining, or send them to the same circuit board refiner in Singapore that off-spec newly manufactured product and warranty return product is sent? If so, the professional warranty-return, manufacturer takeback factory, in an ISO14001 factory, could keep its jobs, buy tested working product, and electively decide to replace working but worn parts, replace 110 volt boards for use in 220v countries, degauss cathode ray tubes for changes in hemispheric magnetic conditions, remove analogue boards and replace them with digital tuners, etc.



- R2 says yes but demands 3rd party certification that the non-reuse constituents were in fact legally recycled in a manner which did not result in release of Annex III constituents.

- E-Stewards says that even if the part is properly recycled, and no toxic is released, that the part must have been removed prior to shipment.

Why WR3A Certification (2007) Woulda Shoulda Coulda

R2 Certification and E-Stewards Certification Growing Pains:  Been There.

silver label for working, repairable, scrap, and dumping

The crybaby e-scrap companies, the public outings of single export loads, the fees to see non-published standards, the waffling by EPA over which standard to endorse... It's a category killer.  The public already discarded ewaste once, and is bound to lose interest if we don't prioritize our goals.   This week someone I know in our business got confused and thought a company in Chicago was "under indictment" (he got confused over the Executive Recycling Colorado indictment).  No, having BAN publicly end your application to be the best company ever does not result in prison.  What my friend's confusion illustrates is the perils of using "certifications" as a substitute for rule of law. We are all attracted to the idea of a simple solution to a complex, robust, multi-niche industry.  As the developer of an earlier fail-to-thrive certification program, I know.