Fiddling with Product Stewardship (as E-Waste Burns)

Product Takeback/ Stewardship advocates and laws have manufactured a System for recycling #ewaste which requires maintenance and stewardship.  The ship of Product Stewardship is seaworthy, but it's headed for an iceberg if the advocates are just focused on the next legal product and don't take responsibility for the takeback laws they already created.

Check the List, Below, of TV recycling company closures and failures.

The "Product Stewardship" movement needs maintenance... or at least some fiddling with.

When devices go obsolete Stewardship advocates make manufacturers "fix the problem".  But what's good for the goose, is good for the gander, right?

Something is broken in E-Waste Stewardship.

As I testified and wrote 5 years ago, electronics reuse markets are so complicated (compared to mattresses, paint, and alkalines) that "e-waste" was probably NOT the best product for wiser Product Stewardship Advocates to start off with.   Now, the list of problems in the electronics recycling infrastructure in "ewaste stewardship" states is growing bigger.   Primum non nocere - "first do no harm" - needs attention.

But that's water under the bridge.  We have these state "takeback" laws now, and a command and control system of accounting for residential TV recycling.

Take a look out the window, my friends.

Here is a brief (and incomplete) list of CRT Recycling Companies which have left the residential TV and computer recycling markets in the Northeast, some permanently. The squeeze of NOT reusing (liabilities in contracts banning exports), and subsequent glutting of CRT glass end-markets (prices better for buyers), has driven up costs, but there's no way to send a Price Revision.  Meanwhile, in NY, NJ and PA in particular, some OEMs reportedly met their "obligations" and left these recyclers, and others, to "pound sand".

My company is still around in part because of our good fortune losing our largest contract - Oyster Bay in NY Long Island, which we lost in 2012.   The OEMs had said they met their goals, and we thank our lucky stars that a competitor talked Oyster Bay into dropping us as a vendor (that competitor is now on the "casualty list" below - focusing on commercial electronics and out of the residential stewardship game).

Others were not so lucky... The Northeast Product Stewardship map has some big holes to fill...

• 2TRG - Ohio Recycler that was part of EWSI Roll up.  EWSI failed to fulfill its financing obligations to Good Point Recycling after GPR invested significant accounting.
• Creative Recycling* - Major service provider on East Coast (including NY, CT, NJ, PA), one of our biggest competitors in NY.
• CRT Recycling (CRTR)* Brockton MA - was one of our largest competitors in MA and NH.
• Eco International NY/PA* - This site was one of the oldest and most respected CRT glass processors in the Northeast.  They reportedly left the largest (12k tons) pile of CRT glass during their bankruptcy.
• Ewaste Recyclers, LLC of Jaffrey, NH closed without finishing the recycling of CRTs they had accepted.
• EWSI Geneva NY -  See 2TRG.  They affected us not only by being a competitor without a sustainable economic plan, but triggered enforcement in NY raising the costs of recycling.
• MPC PA/MN* - One of our backup companies when we ran out of manufacturer obligation in NY, discovered with 2,500 tons unprocessed CRT glass in Philadelphia area.
• North Coast and Kuusakoski did not go out of the residential TV recycling business, but gave up even trying to pay for CRT glass recycling, creating a huge controversy with dumping CRT glass on municipal landfills as "daily wind cover".
• Sims Metal Recycling NY/NJ/Canada - Closed largest e-waste plants this year after $115M annual "write offs" for e-waste.
• StoneCastle - Not a Northeast player, but contacted Good Point to ship dozens of trailers of CRT glass in 2012, 2013 (to Retroworks de Mexico).  We did not execute the PO based on our credit review, but this would have taken us down with them.
• Waste Management Inc. closed its CRT dismantling facility in Springfield, Massachusetts, three years ago.
• WeRecycle* CT/NY - The company went through a brief bankruptcy (shortly after taking over VT one-day events), was purchased by Hugo Neu Recycling, and then withdrew from residential recycling contracts.  Had been one of the largest CED recyclers in CT, NY, MA, RI.

This is probably over 50% of New England CRT capacity, down in flames (figuratively or literally), since the passage of Product Stewardship Legislation in the Northeast.

Some of this is the scrap metal and plastic market - not anyone's fault.  But the largest recyclers in the list failed while scrap prices were at an all time high...

For the past 12 months, we've lost $250,000 just on scrap prices.  The "high" is over.

True, the Product Stewardship laws did create a booming supply, and brought expansion and investment to the industry.  But now, prices for scrap have crashed, and there appears to be little way for large, single-payer contracts like Vermont's to make adjustments.

And it's not just circuit/wiring board.  Steel scrap prices have crashed.  Copper scrap prices have crashed.  Plastic scrap prices have crashed. The price of circuit boards has gone through the floor, following the lowest gold prices since the recession.  As the USA dollar gets stronger, even reuse markets are shrinking.

Good Point continues to meet all of its obligations, paying what is necessary to recycle the CRT glass, at smelters and new CRT furnaces.  But we can't love a business that doesn't love us back.  The cost of Certification (mandatory in Vermont) keeps going up, and the state keeps increasing its insurance requirements.  We need to keep paying our staff a living wage, and that wage should be changing as the unemployment rates fall.

Time for some leadership.

EU E-Waste Policy: White Knights Seeking Middle Ground On a Slippery Slope (Part A)

"Solving the E-Waste Problem"  (StEP) is a European association of highly respected professional and academic experts with strong policy pedigrees.   The "Problem Solving" effort is coming into its eight year.  American environmentalists are keen for European environmental leadership.   The electric windmills fanning the landscape are a testament to proactive policy.

StEP represents itself as a "middle ground" organization.  A lot of us have pandered for that position.  BAN labels us as "apologists".

It is natural to seek to leverage the sensational press around "ewaste exports" and the growing tome of facts about international city junkyards.  Agents of conscience naturally seek a middle ground between the Basel Action Network and...  Facts.  Or is it a middle ground between us and "The Other?"   Otherization, or exoticism, the "informal" six out of seven billion people, who have been labelled so likely to poison their children that it warrants a billion dollars in shredding machines and arrests of African traders.  Since BAN has imposed a kind of "original sin" on anyone who has ever purchased an electronic device, replaced one, or sent one for recycling, we begin with a sense of guilt.   "Agents of conscience" once included exporters, a previous generation of ICT and Internet Access "white knights", organized to heal the "digital divide".

These forces have given rise to another EU based organization seeking "middle ground" between internet access and environmental risk of computer waste.  RecyHub has posted an essay on ICTWorks which follows the path into the "middle ground", or "best of two worlds".  RecyHub has asked me, via Twitter, to review it.    ("They asked for it" is an English idiom).

On the one hand, they get the easy A.  A for "Applaud Anything" that moves Europe from the extremely bizarre far-left arrests of African businesspeople, geeks, and technicians.   Any correction from the 2009-2010 "years of breaking CRT glass", is a gift horse.  But since they asked, I have to tell them... they are at a halfway point between alter-globalization (WR3A) and racist slander.

"Electronic components contain toxics and their manipulation without proper tools can easily release them, resulting in environmental damage and health hazards. Up to now electronics have been mainly used in the most industrialized countries and dumped somewhere else when they reached their (perceived) end of life. Although this trade geography is slowly changing, some countries continue to be known e-waste recipients. Ghana, for instance, is trapped between the desire to modernise by acquiring and refurbishing technology and the damaging effects of it when it’s not reusable...

"After all, they don’t have the technology to process that material properly. E-waste exports must therefore end. That’s why a strict ban like the one proposed under the Basel Convention makes sense (taken even further to forbid any e-waste trade), and why the work of countering illegal trade must be supported. 

One thing I've always loved about Europe is the tradition of arguing sophisticated philosophical positions from a historical perspective.  The Europeans often assume Americans don't do that, that we operate in business from some kind of a "lizard brain", seeking efficiency and profit.

OK, Critique of Part A, in pure reason.

1. Toxics are not "easily released".  Europe had to build shredders, which certainly releases them.  Hand disassembly, harvesting parts and components (down the chips and capacitors and power supplies) is not going to yield toxics.  
2. Up to now electronics have not "mainly" been dumped somewhere else at the end of their perceived life.  
3. "Some countries continue to be known e-waste recipients.  Ghana, for instance, is trapped..."  This is absolutely contrary to the study RecyHub refers to, which says Ghana is NOT an "e-waste recipient" but is a 85-91% reuse recipient which generates 90% of its own "e-waste".
4. "Proper tools"?  A downstroke baler is the most complicated tool we use in Vermont.   The best one we bought used for $2,000.

On the third point, simply visit RecyHub's website, where an entire tab titled "Ghana" offers very scientificky looking "statistics".  It links to a Google Documents Page, with "comment function" enabled, which mostly takes statistics from the E-Waste Assessment (Ghana) study (they should also read the larger Nigeria E-Waste Assessment report).

"9% of the total imports of used equipment is non-repairable and is directly passed on to collectors and recyclers."

The very report they cite disproves most of the allegations.  Nigeria's Assessment was more precise, finding 91% repair and reuse, but we'll accept the 80% estimate from the Ghana study (statistics taken from interviews in the latter case, from actual sea container sorts in the Nigeria study).  In either case, brand new product is as bad or worse.  In either case, the studies explain how Nigeria came to have (World Bank 2007 statistic from 2006 assessment) 6,900,000 households with television.  And cities which have had TVs since Prince Nico Mbarga was on the top 10 are generating junk TVs, just as American and European cities do.

What do developing nations really need?  More development.  And taking away "trade" from the toolkit is exactly what they need least.

Where do "tinkering", "reuse", "recycling", "dumping" etc. fall in Harvard's new Social Progress Index?  If you spend time with people who live in the emerging markets, the developing nations, the cities of the "not yet OECD", their aspirations and measures of progress make Europe and America's obsession with "used electronics dumping" seem obscured by clouds of disinformation.

A Legitimate Concern over Reuse Exports

Jim Puckett, executive director of the Basel Action Network, talked with me about reuse markets in November, at a conference in Las Vegas where we were both making presentations.  To paraphrase William Munny (Clint Eastwood's character in Unforgiven), "It's a hell of a thing," shooting a man's reputation.   So if you'll bear with me in re-tracking the conversation, I will give you legitimate concerns about the free market exports of used CRTs to Africa.   And no, it's not what the press thinks, and the solution is not to ban the trade.

First I'll defend the exporter.  Then I'll say what is really going to go wrong with the exporter's business model in the not distant future.

After Jim's Vegas PowerPoint presentation, I raised my hand and asked him a question about this photo (and accompanying article) in his slide show (artified below).  Jim said he had taken this photo himself, in Lagos.

The UK article he had shown describe the arrest of Joseph Benson, the Nigerian "waste tourist" who purchased TVs in England and shipped them to Lagos (at an average cost of about $10,000 per container).

First, I told Jim that these uniform size TVs did not look like "80% of UK E-waste".   It was actually pretty difficult to put together a full containerload of this size of TV.  I told him the demand for these were the urban ghettos, which often had spliced electricity too weak to light up a (more common) large TV set, and living spaces too small for larger televisions.   I also told him (as I did in 2006 when we spoke following the Charles Schmidt NIH article) that the amount of copper in the 600 or so TVs in the photo would not pay for the $10,000 cost Mr. Benson paid for the container.   At about $3 per burned TV (scrap value), the 600 TVs would only get Mr. Benson about $1,800 of his $10,000 back, and I didn't see how "avoided recycling costs" or "externalized pollution value" would be transferred to him.

Second, I reminded Jim of this result from the 2012 "e-Waste Country Assessment Nigeria"... That of the 600,000 tons (estimated) imports of used WEEE:

Approx. 30% of second-hand imports were estimated to be non-functioning 

(therefore need to be declared as e-waste): half of this amount was repaired 

locally and sold to consumers and the other half was un-repairable. "

You may remember Jim's first response was "Who is Joseph Benson?  I don't know that name".   I told him it was the man's name in the news article he had just shown (arrested) and the likely supplier of the TVs in the container Jim had photographed.   It was not a good response.   I told Jim that according to the math above, that 85% of the container was reused, just as predicted in my 2010 Blog "Monkeys Running the Environmental Zoo", and precisely what I predicted to Mr. Schmidt based on the financial calculations.

Ethical: Samaritan "waste" to slums (The Red Shoe Blog)

The "red show blog" (April 2011) was Tocquevillian.

Why RCRA needs a "good samaritan" rule for Americans trading with people in emerging and converging markets.

Disposal used to mean throwing something into the gutter of a street.  In some of the world's slums, that is still the primary method of waste disposal.   If you throw something into a gutter next to other stuff that is wet and abandoned, you can't really say that you considered the object a valuable commodity.

But what if you were walking the streets of a slum, in India, Pakistan, Kinshasa, and you dropped a $100 bill on the street?  Ethically speaking, is that the same thing as littering?

It could be argued that it was stupid.  Or callous.  Or demonstrated a lack of concern or care whether the $100 bill would do any good to anybody, if it was blown away or trodden into the mud it would have been "wasted".  PREMISE:  Value by itself does not mean that something is not waste.

From the Red Shoe Site blog

But imagine you kept your eye on the bill, and you intended to make sure it was either found, or that you'd come back for it.  You mark where it is thrown by a single red high heeled shoe in the gutter, and watch.  You see a small girl pick the money up, gather excitement, and carry the bill to her parents.   Every day thereafter, the little girl comes to look beside the discarded red high heeled shoe.  Naturally, you'd begin to recognize her, identify her, empathize with her.  You might want to leave a $20 bill by the red shoe again.

Ethically, this is no longer "disposal".   I don't think you would define the bill as "waste".  PREMISE:  If not abandoned, placement by itself does not indicate intent to discard.

Now imagine the object you leave in the slum is a device, something else of $100 "value".   Imagine further that the device contains a circuit board, that it is an "electronic device".   The fact that it is fully functional and working does not mean that it is not waste (premise 1), and the fact that it is exported does not mean it has been discarded (premise 2).   The rules we establish for a $100 bill must also apply to laptops.