Computer Recycling Regulations - A Discussion

Mixed reations to the Federal Task Force on Electronics Stewardship

After a proclamation by President Obama on November 15, 2010, an Interagency Task Force, comprised of the GSA, EPA, and Council on Environmental Quality, was charged with developing an electronics stewarship initiative.   On Wednesday, July 20, they released their report.  Details are available on the EP A website at: http://www.epa.gov/epawaste/conserve/materials/ecycling/taskforce/index.htm

While the proposals from the Task Force are not everything the environmental community hoped for, I wouldn't want to dismiss the progress made with this announcement, and also the responsibility for all of us to hold the government accountable to its established plan. 

I am worried that the strong reactions of frustration by some in the environmental community to the Task Force recommendations will not help the cause.

Here are some of my thoughts.  First of all, I strongly support the e-Stewards certification program, and my IT Asset Disposition company has been certified to this standard.  It is important to recognize that US EPA made it clear that they have no preference of R2 over e-Stewards through this announcement, which is significant given their past involvement in the funding and facilitation of R2 development activities.  That at least raises the bar over the status quo. 

Also, GSA was questioned during the conference call announcement on 7/20 about whether they will require certified recyclers to process their equipment throughout its disposition process.  The federal government disposes of significant volumes of surplus computers through its Computers for Learning donation program and GSAXcess surplus property disposal program.  While these programs can provide great benefits to recipients of surplus property and generate some income for the federal government, they also allow the government to wash its hands of responsibility for the final recycling and disposition of the equipment when the recipient/buyer no longer wants it.  What I heard during the call was that the GSA would re-write its contracts and update its disposal practices to ensure its hardware is properly recycled no matter who is the final user.  I’m not sure how they expect to do this, but we must hold them accountable to this commitment.

On the issue of the US government funding overseas e-waste recycling processes . . . I have personally been involved in the development of sustainable e-waste refurbishing and demanufacturing processing in Ethiopia over the past four years in partnership with the Ethiopian government, World Bank, the International Business Leaders Forum and well respected environmental organizations.  The center was visited in February, 2011 by EPA Administrator Lisa Jackson, who offered the EPA’s commitment to fund the completion of the center and continued technical support.  (See YouTube video about this project: http://www.youtube.com/watch?v=UGN8-S4_nFU).  

I do not agree with Mr. Hershkowitz in his recent blog that by providing a minimal amount of funding in overseas responsible recycling, we are creating an unfettered open channel for cheap US exports of e-waste to developing countries.  The purpose of this program in Ethiopia is to develop domestic capacity for responsible recycling within its border for the e-waste it generates from the use of computers in its country.  It will also help to manage the end of life of used electronics shipped into the country.  Why should the US help with this funding when we have a budget crisis at home?  Because our lack of export restrictions over the years has led to us contributing to the problem of e-waste being dumped abroad.  (Plus, these investments are infinitesimal compared to any other Washington spending.)  Just as we must take responsibility for domestic e-waste processing in the US and must prevent further toxic exports, we must also clean up the mess we’ve made abroad.  Wouldn’t that be novel for our country to do and perhaps go a long way to building bridges with the world?

The government made some good commitments in this Task Force report.  They also seem to express a positive momentum to improve over the status quo.  I fear that a strong backlash against these efforts may erode the opportunity to work together, or to give us the chance to help set the framework for positive solutions on this front. 

Electronics recycling firm denied environmental certification

The announcement yesterday (July 5, 2011) that Intercon Solutions of Chicago, IL was “delisted” from R2 Certification and denied an e-Stewards Certification demonstrates that these third party audit programs actually have some teeth in them.  The grounds for denial are that Intercon exported containers of electronics to Hong Kong in violation of the “e-Stewards standard and it is likely also to violate the importation laws of Hong Kong, the U.S. Federal Resource Conservation and Recovery Act (RCRA) and Illinois state law governing the conduct of registered electronics recyclers,” claims the Basel Action Network (BAN) – the host of e-Stewards. 

Intercon released a statement shortly thereafter purporting it “does not export hazardous waste.”  Depending on how one defines hazardous waste, Intercon might be right, but it can also be the case that they violated the commonly acceptable limitations on e-waste export codified by the e-Stewards and R2 standards.

I know that the e-Stewards review process, in coordination with the certifying body conducting the audit, is required to hear appeals to its decisions.  Jim Puckett of BAN states that they presented clear evidence of the export trail (which anyone can do by tracking container numbers from a generator site to the final destination, see: http://www.track-trace.com/container) and Intercon continued to deny the claim.  Now that government authorities are getting involved, and lawyers have been hired, more information will come to light.

It is clear there is a vast amount of used electronic equipment and parts shipped around the world for commerce, treatment, or cheap dumping.  Some of these exports are for legitimate commerce while others are exported to avoid the proper treatment and recycling that may cost more.  With the recent re-introduction of federal legislation on e-waste exports, the U.S. government can have more resources at its disposal to prevent institutions from externalizing its cost for proper management of e-waste. 

Until that legislation gets enacted (which is low on the priority list of Congress), watchdog groups, the media, social networks, and certifying bodies will be the ones patrolling the industry.  So far, they have exposed companies who claim to be doing the right thing when, in fact, they are not.  Still, there are many companies operating outside of the radar screen who are happy to profit from cheap exports.  It will be interesting to see when they are exposed and what the reaction will be.