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.

Parkour: Do No Harm

I have been under the gun for several important deadlines in the business this month, auditing financials, environmental audits, and managing the huge increase in volume.  I'll probably post some more when in San Francisco (APEC meeting) and Washington DC (Peace Corps 50th Anniversary) this weekend.  It's a cross-country parkour of airports, hotels, conference calls, and bank deposits.

The previous post (Part I) has bugged me for months, and I finally just posted the bugger.  There is something important about horizonal and vertical lobbies, and how interested expertise plays upon cognitive risk perception in the public policy.  E-Stewards is definitely trending towards vertical lobby standards - establishing a standard which keeps out riff raff.  R2, on the other hand, is the first standard to be made mandatory law (Vermont regulations).   I can be arrested and put in jail for not meeting R2 standards.  It has some kind of a burden not to implement a standard based simply on the fact that not everyone meets the standard.  Facts are called for.