This was my comment to the organizers and regulators in the meeting about CRT Cullet Markets (see agenda at bottom):
The culprit, ironically, may be the word "Stewardship".
When we mine gold, copper, tin, iron, tantalum, silver, etc. from mountainsides and Indonesian coral islands, we do massive damage on several scales. Endangered species are exposed by access roads. Children mine coltan to fund warloards. And the number one and number two sources of mercury in the USA are not mercury mining - they are gold and silver mining. The mountainsides release radioactive uranium, leaded dust, mercury, etc. Fourteen of the fifteen largest Superfund Sites in the USA have been hard rock metal mines. But the mountain is not a "Steward".
We still govern mining based on the General Mining Act of 1872. How can recycling compete with standards of yore?
We were involved in the sale of CRT cullet from an alleged "pile" in the southwest which was widely speculated to be non-moving.When we exaggerate the risks of "waste" (attributing more weight to the risk of human-generated secondary material) compared to the risks of identical or higher-risk "virgin" material, we set up bad regulation. The regulations we have established for "Cathode Ray Tube" glass penalize a smelter if they try it as a feedstock.
Cullet from the pile was sold (not through us but using our smelter's same trucking company) to a lead smelter in Mexico, which paid 7 cents per pound.After the 2010 SEMARNAT border controls on the CRT cullet, the Mexico lead smelter said the material was a "headache". They changed in 2012 to charging 7 cents per pound instead of paying 7 cents for the exact same material. That is a change of 14 cents per pound based on nothing but "diligence" which equated (to the mining/primary smelting company) as "risk".This discussion is inadvertently creating justification for companies which speculate on whole tubes, avoiding the cutting and washing. EPA needs to clearly distinguish between diligence on whole unprocessed material and companies which have turned that material into saleable commodity.A shredded toaster (steel pieces) should not carry a label of "toaster waste". It's ferrous metal. The CRT glass which has been processed should be treated as leaded silicate, and governed by MSDS and DOT etc. according to its properties, not as a "waste".
The culprit, ironically, may be the word "Stewardship".
lead mining of yore |
We still govern mining based on the General Mining Act of 1872. How can recycling compete with standards of yore?