Yesterday's Elliot Ness sacasm aside, the link to the federal bill to ban used electronics exports was real. If you work for a scrap recycling company and you are reading this blog and taking the international debate seriously, join ISRI, the Institute of Scrap Recycling Industries (ISRI). ISRI is a large, professional organization with a lot of expertise in markets and processes. My company joined ISRI last year.
We do take exports of junk "ewaste"* very seriously. We have had major difficulties getting USA clients to pay for proper recycling of obsolete and non-repairable electronics when recyclers from the area were just filling sea containers. Our first major competitor in Vermont only failed when he miscalculated how many raw computers would fill a sea container, he ordered the sea container too soon and could only fill it halfway (so I heard). But competition from "sham" recyclers continues to be a big threat to investments and commitments we undertake.
Before joining ISRI, we first tried to join the list of BAN Pledge companies. We had worked closely with BAN before, on the CRT Glass Test, and telling them about the Anaba Market in Lagos. When interviewed by Charles Schmidt of Environmental Health Perspectives (April 2006, still arguably the best written article on the subject of E-Waste), we stressed the many ways that "toxics along for the ride" occurs. When BAN's estimate at the time, "25% to 75%" waste cited in the article, I supported them, saying the 75% is possible if there is a "Cisco router" or something worth a ton of money (though a uniform load of TVs would closer to 25% waste maximum).
Later that year, I wrote to BAN on behalf of my company, telling them where our bad, unrepairable CRT glass was recycled domestically, where our obsolete circuit boards were processed in the OECD, how many employees and plant capacity we had, etc. We did disclose our participation with a manufacturer running a take-back program, and that the manufacturer was not in an OECD country. But I had read the Basel Convention, and under Annex IX there were two ways for the trade to be legal: if no toxics were released, or if the countries considered used electronics "destined" for repair and refurbishing to be a "commodity, and not a waste". I think we got hung up on the word "destined" (even brand new products are "destined" to be waste, if recycling is defined as "waste")..
BAN did not respond to our offer at all for more than 6 months, despite reminders. Finally, they responded that BAN would not accept us as a Pledge Signer unless we ceased doing business with this decent, modern, manufacturer take-back program. I had explained that their company had agreed to earn ISO14001 certification, accept third party environmental audits, and obtain legal import permits. I explained we had proof the CRTs were being reused, and not disposed, and even had film and documentation of the recycling of incidental breakage (e.g. in shipping) and upgraded parts (from repairs or voluntary upgrade of tested working units).
Here things got a little queer. BAN suggested I turn over copies of the permits to them. I asked whether, when I did, we would be allowed to join the Pledge?
BAN said probably not, as they did not consider the import permits legal within the Basel Convention. So... why were they asking for the permits? My guess was that BAN would have located the permit granting office, and appealed the import permit, and my friends in the monitor re-manufacturing plant would have lost their jobs... (I contend BAN did this to other recycling markets - e.g. Samsung Corning, the Fortune 100 CRT glass end market).
I said I wouldn't provide the permit. BAN said it was necessary to provide all downstream market information to join the Pledge. I asked, if that was true, how come the factory was able to get good CRTs from other good Pledge Signers?
Had BAN approved the market for them? Or had the Pledge companies declared the monitors "tested working" (a possible loophole, as the factories did buy those - and remanufacture them with the same "parts upgrades")? Or had BAN never asked, I had simply offered "too much information"?
BAN said they'd be really happy to have my company on the list of Pledge Signers, and I think that was sincere. Of course, if the importer's permits are revoked, I guess BAN thought that would address my objection to leaving the company, and all of us Stewards would be in the same boat (except for one notable cheater they eventually removed from the Pledge list last winter), and we'd be happy ever after. They seemed to think I was motivated by money, and the last response was all about how becoming a Pledge company would allow me to get more clients and income. I guessed they don't really know me, and only valued me as a source of information... I had to decide, like Huck had to decide between Wider Douglas and his stolen property friend, Jim. I stayed loyal to the reformed export market.
That was 3 years ago. Since then, we had this same discussion with EPA (I was a representative of WR3A at the Responsible Recyclers stakeholder group). BAN has had enough time to get a picture of when "the perfect is the enemy of the good." In 2009, when Representative Green's Bill was filed, I realized WR3A is too small to manage this kind of insanity, and joined ISRI. The weekly briefings on scrap markets, safety and OSHA requirements, legislation and law, has been very much worth the membership.
ISRI has also taken the "sham recycling" seriously, and I participated on a group that took export ethics discussion to new levels for their business association.
Whether or not you take this issue as seriously as I do, joining ISRI is a smart move. The Friday Reports on scrap prices, by themselves, are worth the cost of membership.
* ISRI hates the term "e-waste", since it has been used to poison the well before it's even determined whether something is destined for recycling, reuse or disposal.