A new report released today by the Basel Action Network (BAN) documents e-waste which was dropped off at Goodwill sites that partner with Dell for e-waste recycling, ended up being exported to Asian countries, in violation of Dell’s policy not to export e-waste to developing countries. The report titled, “Disconnect: Goodwill and Dell Exporting the Public’s E-waste to Developing Countries,” is the first of several reports from BAN’s new e-Trash Transparency Project.
As part of this two-year project, BAN put 200 electronic tracking devices inside used flat screen (LCD) TVs, CRT monitors, and printers (products that are commonly exported from the U.S. to developing nations) and then turned the TVs, monitors, and printers over to recyclers, charities, and retailers across the country. Then BAN partnered with the Massachusetts Institute of Technology’s Senseable City Lab (MIT-SCL), to map the routes taken by the trackers. The trackers would be easily discovered and removed by anyone disassembling these products for reuse. They are clearly marked with instructions to contact BAN if found. Therefore, it’s safe to conclude that trackers that were exported remained inside whole products.
Today’s report focuses on the results from the trackers inside devices delivered to Goodwill stores. BAN delivered 46 of the total project’s 200 tracker-enabled electronic devices to Goodwill stores around the US— 28 of them at Goodwill stores that are collectors for Dell’s Reconnect program and 18 of them at Goodwill stores not associated with the Reconnect program. Only one of the 18 devices dropped at the non-Dell Reconnect stores, only was recorded as being exported. But six of the 28 devices (21%) dropped at Goodwill stores that were part of the Dell Reconnect public e-waste takeback were exported.
Where did the Goodwill items go?
Of the seven devices dropped off at Goodwill stores, four went to Hong Kong, (one printer and three LCD monitors), one went to Mainland China (one printer), one went to Taiwan (one LCD monitor), and one went to Thailand (one LCD monitor). According to the report, all of these exports were likely to be illegal under international law, and the importing countries’ laws.
Dell partners with many of the Goodwill e-waste recycling programs under their Reconnect Program, whereby Goodwill collects the e-waste and Dell takes it and recycles it. But the exports to China, Hong Kong, and Thailand found in this report clearly violate Dell’s policy of not exporting e-waste to developing countries. Dell has always had the clearest and strongest policy on e-waste exports in the industry. They were the first electronic manufacturer to announce such a strong policy in the U.S. So it’s particularly disappointing to see these results. But not entirely surprising.
There have been several reports from recyclers over the years complaining that Dell (along with some other manufacturers) squeeze the recyclers they work with, paying them as little per pound as possible – less and less every year. Because commodity prices have fallen significantly in the last couple of years, already squeezed recyclers are challenged to manage these products (which contain toxic chemicals) responsibly without losing money. The three product categories in this study – LCD TVs, CRT monitor, and printers – are all money losers for recyclers at this point (assuming the panel from the LCD has no reuse value). So it’s not a big surprise to see these items go down the low road. While Dell has one of the toughest audit programs in the industry for their takeback system, no audit program can compensate if you don’t pay recyclers enough to manage the commodities responsibly AND make a little profit to stay in business. Not unless you are monitoring every single shipment.
So if this is happening to Dell, the company with the highest standards and toughest audits, should we assume that other manufacturer takeback programs’ e-waste is also being exported to developing countries, even if they have a policy forbidding it? Stay tuned to BAN’s e-Trash Tranparency Project’s upcoming reports.
Amazon, do we really need these little devices?
Amazon, retail’s undisputed King of Laggards on sustainability and environmental efforts, has just added another jewel to its tarnished laggard crown by expanding its Dash button program. Last week, on the one-year anniversary of the introduction of the Dash button, Amazon announced it was tripling the number of buttons to include a wider range of products and brands.
In case you’ve missed it, a Dash button is an electronic, Wi-Fi connected device that lets you order a specific product from Amazon by just pushing the button. The idea is that you stick the button for that product next to the place where you use that product. When you see that you are running low, you just press your dash button, which immediately reorders that item from Amazon for you using your Wi-Fi. You must be an Amazon Prime member to buy the Dash button. Of course, delivery comes via Amazon Fresh, its home-delivery service.
Setting aside our bewilderment about why anyone would be willing to glue these fat plastic lozenges bearing corporate logos around the house, we can’t help but notice that these buttons seem more like future e-waste than must-have devices. The buttons each do only one thing – order a very specific product, in a specific size, from a specific retailer. You will have a few options of which Tide product you can configure your Tide button to order, but you can never switch it from being a Tide button to another brand’s button.
So what happens when you decide to use a different brand of product? Or you decide to buy from Costco instead of Amazon? Or realize you can just write the item on your shopping list? Or use your phone to make a one-click order on Amazon? Or the (non-rechargeable) battery runs out? What will consumers do with the now useless Tide button?
Our guess is that most people will just toss it into the trash, unaware that there is a AAA battery inside, plus a circuit board and electronics – things that should be recycled, not trashed.
They should be recycled because they likely contain some of the toxic chemicals commonly found in electronics, which shouldn’t end up in the landfill. Plus they contain metals and plastics which should be reused, not trashed, as they are not renewable resources.
Amazon Won’t Recycle Dash Buttons
Yet there is no information on Amazon’s website about returning a Dash button. I contacted Amazon’s customer service department, which told me they do not accept them back for recycling or reuse, but that I would be free to recycle one on my own. I doubt that a recycler will even want this, since the cost to take it apart to remove the battery probably exceeds the commodity value of the parts. So the Dash button will become a trash button anyway.
Amazon, seriously, you need to take these things back to reuse and recycle them. Or even better, focus on other strategies for customer loyalty that don’t add to the e-waste pile.
Worsening economics of recycling drives changes
Best Buy today announced some significant and unfortunate changes to their electronics takeback and recycling program. First, they have instituted a steep fee of $25 for every TV or monitor collected for recycling. This applies to CRT (tube) TVs/monitors as well as flat panel TVs. They will continue to take other products back for free. Second, they have removed the requirement that their recycling vendors be certified to the e-Stewards standard, which is the highest standard in the marketplace particularly on requirements for worker health and safety and exporting e-waste to developing countries. Certification to e-stewards is now optional for their vendors.
Best Buy, the largest consumer electronics retailer in the U.S., stated their goal is not to dissuade customers from bringing back TVs, but they simply need to cover their increasing costs of TV recycling. The Electronics TakeBack Coalition (ETBC) doesn’t dispute the fact that the economics of TV recycling are bad – there is almost no market for used CRT glass, and commodity values for other materials from electronics (plastic, steel, and other metals) crashed in 2015, and continue to slide downward. While we recognize that Best Buy seeks to cover its costs, we believe that most people will find the $25 fee too high, and may be driven to trashing, dumping or using irresponsible recyclers.
In the 25 states with no takeback laws, Best Buy has been pretty much the only recycling game in town, or even entire counties, for electronics recycling, particularly for big stuff like TVs. (Staples has a good takeback program, but they don’t accept TVs. Goodwill (partnering with Dell) also offers takeback in many areas, but again, they are increasingly saying no to TVs.) So in many places, the choices for consumers who want to get rid of an old TV have been: a) take it to Best Buy, b) put it in the landfill (still legal in many states), or c) dump it on the sidewalk or someplace else illegally.
Other big retailers still doing appallingly little
Meanwhile, Amazon and Walmart, who were the number 3 and 4 consumer electronics retailers in 2014, continue to do nothing very meaningful to help consumers recycle all the products we are buying from them, especially the big stuff like TVs. These retail giants are part of the enormous marketing engine that drive consumers to buy, buy, buy. And they should be doing much more to make sure all this stuff gets reused and recycled responsibly. ETBC did a Retailer Takeback Report Card in 2013, which found that other than Best Buy, Staples and Office Depot, other retailers were doing very little. Amazon and Walmart flunked, getting F’s. Now in 2016, little has changed. We continue to encourage consumers to stop buying electronics from retailers who do little to encourage and facilitate recycling and reuse of old products.
Manufacturers are ultimately responsible
But ultimately, it’s the manufacturers who have the most responsibility here. While many of them do have takeback programs, most do little or nothing in the states where the law doesn’t require them to. Most offer mailback recycling programs, but most consumers don’t use them except for trading in high value items like smartphones. People want to drop off their old stuff at a physical location, and not bother finding a box and packing it up to ship for recycling. This is particularly true for the big stuff – monitors, TVs, printers and multi-function machines.
Many states have passed “producer responsibility” recycling laws, requiring manufacturers to take back and recycle old products. But over time, we have seen that with a few exceptions (notably Samsung, Dell, LG and Best Buy) most manufacturers will do only what the law requires, and nothing more. That means not offering physical collection sites if it’s not required. For states which have annual collection goals, once the manufacturers hit their goal, they stop collecting for the rest of the year.This makes it difficult for consumers who want to have ongoing sites where they can bring their old products.
Another problem is that many manufacturers have been squeezing their recyclers, by paying lower and lower prices per pound, putting enormous pressure on an industry that’s already reeling from the drop in commodity prices – the prices for which they can sell the materials in our old products once they disassemble them. A good example of this is that fact that several recyclers have ended up stockpiling thousands of tons of CRT glass, because (in some cases at least) they didn’t get paid enough by their manufacturer clients to cover the high cost of responsibly processing this lead-laden glass.
Lowering the bar on recycling standards
The second part of Best Buy’s decision was to remove the requirement that Best Buy’s recyclers be certified to e-Stewards. There are two certification programs for electronics recyclers in the U.S. – e-Stewards and R2. Until recently, Best Buy required recyclers to be certified to both standards. Now, they can be certified to either e-Stewards or R2. Best Buy stated that this was a cost-cutting measure, and adhering to the R2 standard is cheaper for recyclers. Of course, there’s a reason for that – R2 is a less rigorous standard. So to save money, Best Buy may be working with vendors who are less diligent about where their stuff goes and how it’s processed. In other words, their costs could be easily externalized to poor communities in developing countries.
What should Best Buy do?
ETBC is disappointed by today’s news from Best Buy, who has been a leader on takeback and recycling for many years. But we recognize the larger economic conditions that have led them to look for cost cutting options. (Although we do think they should not charge consumers who bring back any of Best Buy’s house-branded TVs.) The solution here would be for the manufacturers – particularly the TV companies – to visibly partner with Best Buy to cover some of the recycling costs, and to make sure that responsible recycling occurs. The TV companies, who are always challenged by finding collection sites, could take advantage of the chain’s huge network of stores, which are very convenient collection points for most consumers. This would be an ongoing national partnership program, in every state, in every store, co-marketed by the retailer and the industry. This could also be established with Walmart and their huge network of stores. While Amazon doesn’t have stores, there are many ways in which they could help to be part of the solution.
White House says EPEAT is currently the only tool available that meets its electronics stewardship mandates
The Executive Order had created a problem when it revoked a previous Order requiring that the federal government use the EPEAT label to guide at least 95% its electronics purchases, and then left the door open so that agencies could use basically any standard meeting some very low-bar requirements. The Electronics TakeBack Coalition considered this Executive Order language to be an open invitation for some non-leading electronics companies (or their industry association) to establish a new eco-label that is not as strong as the EPEAT criteria, and would be easier to meet.
Others shared our concerns, and many public and private institutional purchasers, who use the EPEAT label to guide their electronics purchasing, joined us in providing feedback to the White House on the perhaps unintended consequences of the Order.
What the Implementing Instructions Say
The implementing instructions fix the problems and confusion created by the Executive Order by:
- Closing the door it threw open for other weak standards to be used, by clarifying that other standards can only be used if the EPA doesn’t have a recommended standard for the product category. This was a specific recommendation that many of us made to the White House. The EPA already recommends using EPEAT on its greener products website and it’s hard to believe they won’t continue to do so.
“Where there is no specification, standard, or label recommended by EPA, an agency may elect to use other open and voluntary standards in a procurement.” Page 56
- Clarifying that even though it removed the EPEAT mandate, EPEAT is the only label that meets its requirements:
“Unlike prior executive orders, E.O. 13693 does not include a specific reference to Electronic Product Environmental Assessment Tool (EPEAT). However, EPEAT is currently the only tool available to achieve the electronic stewardship mandates of section 3(l) of E.O. 13693. Any future tools shall meet or exceed current levels of sustainable and environmental performance.” Page 65
- Raising the requirement for purchasing products meeting the recommended standard from 95% to 100% of electronics purchases:
“Unlike prior executive orders, E.O. 13693 requires that all applicable procurements, rather than 95%, of purchases for electronic products be environmentally sustainable including those electronic products typically used in office spaces and data centers.” Page 65
The Electronics TakeBack Coalition commends the Federal Environmental Executive Kate Brandt and her team for including this clarifying language in the implementing instructions. We recognize that at some point there may be competing labels that are “as good or better” than the current EPEAT label, and that the EPA may recommend using them in addition to EPEAT.
We only hope that these labels or standards will choose to become part of the EPEAT program (even if they were not developed under the EPEAT system) and place the qualified products on the EPEAT registry. This is important because it’s this one-stop-shopping aspect of EPEAT – having all of the information on qualified products in one place – that makes the EPEAT program so attractive and effective for purchasers.
Order will lead to death of purchasing program for greener electronics
President Obama’s recent Executive Order 13693 set forth some excellent lead-by-example goals for how the federal government must reduce energy and water use, reduce greenhouse gas emissions, and promote alternative energies.
But it contains some seemingly harmless legal jargon, that if left unchanged, will result in the death of the federal EPEAT program for purchasing greener electronics.
The EPEAT program gives purchasers a way to identify electronic products that meet a set of environmental standards. The program has been used for several years by federal purchasers, state agencies, universities, non-profit, and private companies in the U.S. and increasingly in other countries. But now the Obama Administration is turning its back on this very successful program.
While this Executive Order is titled, “Planning for Federal Sustainability in the Next Decade,” it’s mostly about energy, energy, energy, water, and energy. But with this order, the Administration also quietly revoked the two previous Executive Orders (13423 and 13514) which established and maintained the very promising (albeit wonkily named) EPEAT program for electronics and which also required that 95% of the electronics purchased by federal agencies must be registered EPEAT products (for those categories where there is an EPEAT standard).
The EPEAT standards include energy efficiency, but also many other crucial sustainability issues, like limiting the use of hazardous chemicals, design for recyclability, sustainable materials use, use of certified recyclers, and sustainable packaging.
Federal agencies won’t have to buy EPEAT products
The new executive order never mentions EPEAT. It does try to claim to “promote sustainable acquisition and procurement” and specifies two ways for federal agencies to do that, beginning with the new fiscal year (October 2016). One way is to purchase environmentally preferable products or services that meet or exceed specifications, standards, or labels recommended by the EPA.
But it’s the other method (Option B) that spells the beginning of the end of the EPEAT program. With these references, the Executive Order allows federal agencies to buy products that meet practically any kind of voluntary standard, as long as the standard was developed using a so-called “consensus” stakeholder process:
(B) meet environmental performance criteria developed or adopted by voluntary consensus standards bodies consistent with section 12(d) of the National Technology Transfer and Advancement Act of 1995 (Public Law 104-113) and OMB Circular A-119.
“Consensus” process doesn’t mean a fair and balanced process for standards development
That sounds good, right, using voluntary standards developed by a “consensus” process including a wide group of stakeholders to identify what’s a preferable product? But in reality, the use of a so-called “consensus” process is no guarantee that the standard will be a strong standard, or provide meaningful guidance for federal purchasers to identify greener products. In fact, when it comes to sustainability standards, these consensus processes can be quite the opposite. They are easily dominated by companies that make and sell the products (and the chemical companies that supply them) despite other stakeholders participation. And many manufacturers typically don’t support criteria in these standards (even optional ones) that their products can’t already meet. So sustainability standards developed under the usual “consensus” process (without some additional requirements) are not likely to set a very high bar for sustainability.
That’s because most of these “consensus” standards use rules (“essential requirements”) developed by the American National Standards Institute or ANSI, which allow any single category of stakeholders to have as much as half of the votes, and calls that “balanced.” Any industry association can put together a process that technically meets that very low bar of a consensus standard, and then simply take what the industry is already doing and brand it as “green.” If this language is allowed to stand, government purchasing standards will devolve into a “lowest common denominator” approach favored by ANSI rules.
Strongest sustainability standards go beyond ANSI rules
In fact, this is such a problem that the strongest sustainability standards being used today – including LEED standards for green buildings, the Forest Stewardship Initiative (FSC) standard for lumber, and Fair Trade standards for farmers and other producers around the world (to name just a few) were developed outside the ANSI process because the groups developing them wanted to avoid the manufacturer domination that occurs with so many “consensus” processes. You can see the difference by looking at the high-bar standards’ weaker counterparts, developed under the ANSI rules, like Green Globes (for buildings) and the Sustainable Forestry Initiative (SFI) for lumber.
Why would the administration allow such a low bar for environmental standards, when they could easily have pointed to the EPA’s Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement? The EPA has done some very good work over the last four years developing guidelines for what kinds of standards and labels are worthy of the federal government’s use. Their current draft (about to be piloted) includes not just attributes of how the standards are created (like transparency, and balance), but also other critical things like whether there is an entity attached to the standard that can actually verify whether those claiming to conform to the standard actually do so.
Did the Administration unwittingly make these changes that spell the end of EPEAT? Or did the Obama Administration yield to pressure from the electronics industry? We know that the federal government has been the target of a relentless lobbying campaign by the industry association, the Information Technology Industry Council (ITI), who is unhappy with the EPEAT program, which has some additional guidelines that go beyond ANSI . In fact, after much debate, ITI lost a key internal struggle in 2013 when the EPEAT stakeholders voted to leave IEEE as their standards development organization (SDO) because of their unfair rules and switched to NSF as an alternative that provides a more level playing field and a more balanced process. Fearing a loss of their control of the process, ITI retaliated and started their lobbying campaign against EPEAT. Given the current language in the Executive Order, their campaign seems to have been successful. Even though there has been a robust stakeholder group (including ETBC) working productively over the last 18 months to resolve the concerns raised by the electronics companies with EPEAT program administration and verification, their lobbyist has continued to press for steps that will kill the program.
Will this Administration be remembered for killing EPEAT?
We are surprised that Obama Administration would want to be known (among other things) as the Administration that killed the EPEAT program. What a shame, after so many years of time and effort by so many people to help the government use its purchasing power to promote sustainability.
But that will be their legacy if they don’t take some immediate action to undue the harm they have set in motion. Today, we sent the Obama Administration a letter outlining the changes they could make to stop this unfortunate trajectory:
- They could modify the Executive Order to remove Option B and add in EPEAT; or
- In their implementing instructions to agencies for carrying out the order, they could:
- Recommend the use of EPEAT for electronics purchases; and
- Allow purchasers to use the consensus standards option ONLY if the EPA cannot recommend another standard or label for that product category
This can be fixed but only if the Whitehouse takes swift action.
NOTE: If you are with an organization, company, agency, school, or a certified electronics recycling company who would not like to see the EPEAT program disappear, please let the Whitehouse know. Send a letter to the Federal Environmental Executive, at the Whitehouse.
Click here for a sample letter.
An e-waste broker in Michigan pleaded guilty last week to illegally shipping used CRTs to Hong Kong and China, and falsifying export records which stated the shipping containers contained plastic and scrap metal.
According to the Department of Justice, Michigan resident Lip Bor Ng, also known as Paul Wu, repeatedly exported CRTs to Hong Kong and China, without filing the appropriate paperwork with the EPA, and without attaining the required consent from these countries to accept this hazardous waste, as required under the EPA’s CRT Rule . Ng faces a maximum sentence of five years imprisonment and a $250,000 fine. Sentencing is set for July 14, 2015.
Export records don’t tell the real story of e-waste exports
This case is a great example of activity we believe occurs on a regular basis. People acting as export brokers (often very small operations) load up containers of CRTs, and lie on their customs documents where they declare the contents of the shipments. In this case, the exporter said he was shipping plastic and scrap metal, not CRTs. This is the reason why research on e-waste exports that is based on official export records is very unreliable, and grossly understates the amount of e-waste being exported. Smugglers are not going to say they are exporting CRTs. This is illegal to export from the U.S. to China or Hong Kong, and it’s illegal for those countries to receive it. So the exporters lie about the contents, and say it’s plastic or scrap metal.
We believe the volume of illegal CRT exports is increasing, because of the high cost of managing CRT glass, which is laden with lead, and contaminated with toxic phosphor powder, in a responsible manner. Part of the problem is that there are few options for where to send CRTs for legal processing, as CRT manufacturing has been replaced by flat panel production globally. And the few remaining options are expensive – they cost recyclers money, as opposed to earning them money.
Incentives to export CRTs greater than ever
As a result, we have millions of pounds of CRT glass being stockpiled in warehouses, outdoor heaps, and containers across the country, largely collected by recyclers who can’t afford to send them to smelters or other processing. Some of these pounds were collected on behalf of manufacturer takeback programs, but recyclers did not get paid enough to properly manage the glass. So there it sits. With the cost of CRT processing being as high as it is, there is more incentive than ever to simply export whole CRTs out of the country, as that Michigan broker has been doing.
This case involved collaboration between the Dept. of Justice, the EPA, and U.S. Immigration and Customs Enforcement, and the U.S. Postal Inspection Service. We applaud these agencies for their work to investigate and prosecute this case. We hope they will continue their efforts to stop these illegal exports of hazardous waste.
NGO’s today delivered a formal challenge to the electronics industry to take action to stop the harm to workers and communities caused by hazardous chemicals used to manufacture electronic products. The Challenge, endorsed by over 200 labor, environmental, public health and community organizations in 40 countries, was presented by a representative from Good Electronics to a meeting in Brussels of the Electronics Industry Citizenship Coalition (EICC), a trade association created to help the industry address environmental, human rights and “social” problems in its supply chain.
The EICC’s “Code of Conduct” that addresses environmental, labor, and health and safety issues, is pretty weak. But its biggest problem is that the EICC system relies upon occasional audits to enforce conformance to this code of conduct. There is plenty of evidence, including a 2014 ICAR report called “Turning A Blind Eye,” that this kind of occasional audit system simply doesn’t work when it comes to the kinds of supply chain issues occurring in the global economy that places manufacturing in developing countries with low wages, weak laws, weak enforcement, and high incentives for corruption. Business for Social Responsibility came to the same conclusion back in 2007 in its Beyond Monitoring report. In fact, at a January 2015 meeting between EICC and membership groups from both ICRT, and Good Electronics, industry representatives stated that problems of cancer and deaths from hazardous chemicals doesn’t even show up as a problem in its audits. Clearly, there is a major disconnect between what’s really happening, and what the occasional audit program can see.
The problem of chemical harm from electronics manufacturing is not new to this industry that uses many highly powerful solvents, acids, and other highly toxic chemicals. After the supposedly “clean” semiconductor industry came to Silicon Valley, hundreds of cases have emerged of workplace exposure causing harm to workers and their children and to nearby residents who were exposed to contaminated drinking water polluted by chemicals from electronics factories.
But these problems continue today, now spread to the various countries where the electronics industry now manufactures its products. Civil society organizations report hundreds of cases of electronics production workers who have fallen ill over the past five years in China, South Korea, Indonesia, Philippines, Thailand and elsewhere, from exposure to benzene and other highly toxic chemicals used in manufacturing.
Just a few examples:
Leukemia at two Samsung plants in Korea
Supporters for Health and Rights of People in the Semiconductor Industry (SHARPS), a worker rights group in South Korea, has documented a total of 193 workers who developed cancers or other illnesses at various Samsung plants in Korea, 73 of whom died. Victims and families of workers who died have been challenging Samsung in court to compensate them for the illnesses and deaths. Last year, Samsung finally issued an apology to the families, and agreed to provide some compensation, but fell short of admitting any responsibility for the illnesses.
SHARPS has also identified another 50 victims at other (non-Samsung) semiconductor plants in Korea, 19 of whom have died.
Workers at RCA plant in Taiwan
Workers at the now-closed plant of RCA in Taoyuan County, Taiwan, say that toxic chemicals caused nearly 1000 cancer cases, and 157 deaths. Following a long legal battle in a lawsuit filed by former workers, a Taipei court is expected to issue a ruling in this case in April 2015.
In June, Dutch research center SOMO will publish a report together with Labour Action China (LAC) on benzene poisoning in the electronics industry in China.
Areas for Action
The Challenge was developed by members of two global NGO networks: Good Electronics and the International Campaign for Responsible Technology (ICRT), to which the Electronics TakeBack Coalition belongs. The document challenges the industry to take action in six key areas:
Be transparent. Provide full materials disclosure to workers, communities, and the general public, including what chemicals are being used and discharged, and what hazards to the environment and humans (including reproductive hazards) are known to be associated with the chemicals.
Use safer chemicals. Assess hazardous materials used in manufacturing throughout the product lifecycle and replace them with safer alternatives. Where the environmental or human health effects of a substance are unknown, its use shall be avoided; where it is inadequately or incompletely characterized, the precautionary principle shall apply until all relevant hazard testing is available.
Protect Workers. Develop and implement, jointly with affected and other interested workers and their organizations, comprehensive hazard monitoring for all workplaces and workers throughout the product lifecycle. This includes training, capacity building, and industrial monitoring as well as monitoring to measure exposures and health surveillance to identify and prevent diseases. Workers shall be able to negotiate over hazardous working conditions and refuse hazardous work without fear of retaliation.
Guarantee participation. Respect efforts of workers and communities to participate in the sound management of chemicals and wastes in their workplaces and communities. This includes the development of effective worker health and safety committees and training programs.
Protect communities and the environment. Prevent harm throughout the product lifecycle. Conduct effective, transparent, independent monitoring of all discharge streams. Eliminate hazardous discharges to air, waterways, and land.
Compensate and remediate for harm to people and environment. Develop and fund mechanisms that ensure that workers (present and former, and their families) or communities harmed by exposure to hazardous chemicals receive emergency relief and just compensation. Develop funding mechanisms to ensure environmental and workplace remediation for as long as is needed to address the harm.
Read the full text of the challenge here.
Dell has announced that later this month they will begin selling their first computer (the OptiPlex 3030 all-in-one) made with plastic recycled from old electronics. With this announcement, Dell is launching its pilot for a closed-loop recycling of plastics – turning plastic from old electronic products into new ones rather than dumping them into the usual e-waste cycle. Dell told ETBC that the move is, in part, in response to increasing requests from purchasers for closed-loop recycling.
Closed-loop recycled plastics have been used in ink and toner cartridges for printers, but this is the first time that we are aware of plastics from recycled electronic products going into a large part of the product itself. Manufacturers have also used recycled plastics in enclosures before, but they came from recycled water bottles or CD cases, not from used electronics. While this may not seem like an important distinction, we think it represents a very significant step towards a more sustainable product lifecycle, and an important milestone for the concept of Producer Responsibility.
Why closed-loop recycling matters
Typically, plastic enclosures from old computers and TVs (which are fairly large pieces of plastic compared to other electronic products) do get recycled. Recyclers send most of these plastics to China where they are “down-cycled” into a lower-grade plastic, used in products like outdoor furniture, or decking material. With a closed-loop system, the plastics from electronics are recycled into new electronics or other products where the plastics are of the same quality. This offsets the use of some amount of virgin content in manufacturing the new electronics. Currently the parts of the OptiPlex made with closed-loop plastic (the back panel and stand) contains 35% recycled ABS plastic, and 65% virgin ABS. Those parts represent only 12% of the plastics (by weight) used in the product but it is an encouraging start. Dell says they hope to increase both the number of parts where they can use the recycled plastic as well as the percent of recycled plastic compared to virgin plastic. They also plan to add the recycled plastics to other desktops and monitors later this year.
Pilot is a logical outgrowth of Producer Responsibility
Several years ago, Dell accepted and embraced the concept of Extended Producer Responsibility (EPR), which says that the manufacturers should be responsible for the full lifecycle of their products, including the “end-o-life” phase, when consumers want to dispose of them. As a result, Dell has developed a fairly robust program throughout the U.S. to take back and recycle its old products, as well as those of other manufacturers. Because Dell manages its own recycling vendors (and doesn’t use a network of recyclers managed by others) they retain control over what happens to the materials – including the plastics – from these products. For this initial pilot, Dell will focus on plastics coming back from its takeback programs in seven states. The plastics will be recycled by Wistron Green Tech, a Texas-based subsidiary of a Wistron Corporation, a Taiwanese original design manufacturer (ODM). Dell’s goal is to use 50 million pounds of closed-loop recycled plastic by 2020. They will focus on two types of plastics: ABS and PC-ABS. The plastics will be recovered both in the U.S. and in China, but even the U.S. processed plastics will be shipped to China for manufacturing into new plastic parts.
Scott O’Connell, Dells Director of Environmental Affairs, tells us he expects this closed-loop program to drive U.S. recyclers “to improve recovery rate of plastics by creating an upcycle market that did not previously exist in large scale.” He expects this drive even more plastics recycling as other manufacturers also start to use the closed-loop recycled plastics.
Ultimately the goal for closed-loop recycling is to keep using the materials over and over again, maintaining the same grade and value of the material. The sustainability metric here should be to create “infinitely recyclability” where the materials can be used indefinitely, with the addition of very little virgin content. While some metals are infinitely recyclable, the plastics being recycled in this pilot – ABS and PC/ABS – don’t currently meet that goal. But this may be the first step of many towards a system where materials are selected and used with increasing recyclability in mind. If the electronics sector followed Dell’s lead and embraces the closed-loop recycling concept, perhaps we will eventually see the development of plastics that would come closer to being infinitely recyclable.
Frankly it’s rare for the electronics manufacturers to even talk about the circular economy, so we are glad to see Dell leading the way in bringing this issue forward. To all the purchasers out there who have been asking about closed-loop recycling or the circular economy in your equipment RFPs and questionnaires, your efforts are paying off, and Dell is clearly listening.
Samsung took an unprecedented step on May 14, and publicly apologized to workers who developed cancers after working at Samsung semiconductor plants. Some of the workers have died from leukemia. Samsung vice chairman and CEO Kwon Oh-hyunpromised compensation to the victims’ families, but made it clear that it does not concede that Samsung is responsible for the illnesses or deaths. They also promised to stop intervening in the worker compensation lawsuits filed by the victims’ families.
The admission is the direct result of years of tireless public campaigning by the families of the victims, worker and public health activists in Korea who comprise an organization called SHARPS: Supporters for the Health And Rights of People in the Semiconductor industry. Their cause gained attention with the release in Korea of two films earlier this year showing the victims and their families’ battles with Samsung.
One film called “Another Promise” tells the story of the first victim, Hwang Yu-mi, who died from leukemia in 2007 at age 23, and her father’s fight to bring this hidden issue into the light. Like many other Samsung workers, Yu-mi came to work at the Samsung plant in 2003, while still in high school. She was diagnosed with leukemia just two years later, and died two years after that. Other victims followed a similar path – they are largely young women who started work while in high school, and soon developed blood cancers and other illnesses not usually found in people so young.
While Samsung denied any connection between their plants and worker illnesses, the connection seemed obvious to Yu-mi’s father, a taxi driver, when her co-worker, another young woman working at the work station, also developed leukemia a short time after starting work there. She died a few months before Yu-mi. Over time, a disturbing pattern of blood cancers – leukemia and lymphoma – emerged at two plants. At least 35 workers from both the Gi-heung plant (where Yu-mi worked) as well as the On-Yang fabrication plant have developed these blood cancers, with ten dying since 2007. The documentary film, Empire of Shame, follows Mr. Hwang and other activists in their efforts to uncover other victims from chemical exposure in the semiconductor industry.
SHARPs formed to address this growing problem, and began keeping statistics on cancers, illnesses and deaths in semiconductor and other electronics manufacturing facilities in Korea. They say that more than 193 workers at various Samsung factories in Korea have developed cancer or other diseases, and 73 of them have died.
| Occupational Illnesses and deaths at Samsung manufacturing facilities in Korea
Data source: SHARPS
|Mobile phone, Electronic components||10||7|
|Samsung Electromechanics||Electronic components||12||8|
|Samsung Techwin||Camera, Robot, Other microelectronics||4||0|
|Total Samsung Korea||193||73|
|Other semiconductor companies Korea||50||19|
Companies need to look for the warning signs
Samsung responded to the workers’ claims by saying they were not using cancer causing chemicals. But the sad reality is that we often learn that chemicals cause harm (including cancer) after they are put into commerce – and the workplace is often the testing lab. Industrial chemicals are largely unregulated worldwide. In the U.S. of the more than 80,000 chemicals in commerce, only a few hundred have been tested. So it’s simply not adequate for manufacturers to conclude that just because a chemical is not on a list of harmful chemicals, that it’s safe. It’s more likely not to have been tested adequately.
With all of the blood cancer cases that SHARPs has documented, there were often warning signs that something was wrong. Fatigue, dizziness, bruises. Dermatitis or respiratory diseases. Miscarriages in young women with no family history of miscarriages. Birth defects in children born to workers. These illnesses and deaths reflect similar patterns experienced at IBM in Silicon Valley and throughout the United States, during the heyday of electronics manufacturing there in the 1980s and 1990s.
This is why we think it’s important for semiconductor and other component manufacturers using such highly toxic chemicals like solvents to do regular health monitoring of their workers, as well as workplace exposure monitoring, and to carefully track that information over time. Chemical exposure may not develop into cancer until many years down the road, but there may be warning signs if anyone is paying attention to them. Tracking the workers’ health problems (including reproductive health problems) and symptoms can point to patterns and possible links to exposures. We think this is the responsibility of any company using toxic chemicals, especially since so little safety and health testing is done on chemicals before they start using them. They also need to fully inform the employees of the chemicals they are using, as well as provide them full access to information about the potential harm from the chemicals and how to protect themselves. Ultimately, the manufacturers need to find safer substitutes for the harmful chemicals, or different processes that use safer chemicals and materials. But in the meantime, they need to play an active role in protecting their workers and the community from exposure and harm.
Samsung, government deny victims compensation.
One of SHARP’s primary roles has been to help the victims or their families fight for financial compensation for the medical costs and pain and suffering. And “fight” is the operative word here. Once the workers have been diagnosed and become unable to work, they (or their families) have filed claims with the Korean Workers Compensation and Welfare (KCOMWEL) for compensation and, in some cases, funeral expenses. KCOMWEL is a state run workers compensation program. But Samsung’s worker comp premium rates are linked to their number and severity of successful claims so Samsung has encouraged KCOMWEL to deny these claims, saying there was no proof that they are related to work. After KCOMWEL denied their claims, some of the victims and families have filed lawsuits to challenge the denials.
In 2011, the workers finally caught a break in the otherwise steady stream of denials. The court ruled in favor of two workers who had died from leukemia. Then in 2012, the worker comp agency (KCOMWEL) ruled in favor of a worker for the first time, and recognized that the aplastic anemia suffered by a worker as an occupational disease resulting from her work at Samsung Semiconductor’s Onyang factory.
But it’s still been a largely uphill battle. This Sunday, June 1, marks the seven year anniversary of when Mr. Hwang (Yu-mi’s father) first filed his worker compensation case with the government, which denied him any compensation. Mr. Hwang won an appeal of that decision with the administrative court, but the government appealed that ruling, so it’s now before the High Court in Korea. Samsung formally intervened on behalf of KCOMWEL, assigning attorneys to help with the appeal against Mr. Hwang’s case. Samsung’s announcement earlier this month included a statement that the company will stop this kind of intervention in these cases.
Dr. Jeong-ok Kong, an MD with the Korean Institute of Labor Safety and Health, and an active participant in SHARPs. She told us that Mr. Hwang continues this difficult and emotionally draining fight primarily to help others in the same situation. “He really wants Yumi’s case to be recognized and compensated as occupational disease by the law, because there are many other workers from different factories from Samsung suffering from occupational illness.”
 Int J Occup Environ Health. 2012 Apr-Jun;18(2):147-53. doi: 10.1179/1077352512Z.00000000019. “Leukemia and non-Hodgkin lymphoma in semiconductor industry workers in Korea,” Kim I1, Kim HJ, Lim SY, Kongyoo J. http://www.ncbi.nlm.nih.gov/pubmed/22762495 (subscription required)
Battery maker Rayovac pulls out of battery recycling effort
Friday is America Recycles Day. As you may know, we’ve made some huge strides on electronic waste recycling in the last ten years. Many states now require computer and TV makers to take back and recycle used electronics. Many of the electronics manufacturers have serious takeback programs even in states which don’t mandate them.
But we are not seeing the same effort from the manufacturers of single-use batteries – the ones you can’t recharge – that we use by the millions in remotes, cameras, clocks, and many small electronics and toys. And there’s one company that is the main obstacle in moving forward on battery recycling – Rayovac. That’s why we’re joining with many other recycling advocates across the country to send a message on America Recycles Day (November 15) targeting Rayovac as the 2013 Recycling Laggard.
When ETBC started its campaigning back in 2001, the electronics companies were already providing recycling to people in the European Union and some Asian countries – but had no plans to do the same for the U.S. We mobilized and started pressuring Dell and then other companies to recycle, and we worked to pass state laws across the country. We’ve come a long way since then. Now the situation isn’t perfect, but there are many more opportunities for responsible recycling in the U.S.
But with batteries, it’s déjà vu. Canadians and most Europeans have convenient battery recycling – but not us here in the U.S., even though we use over 180,000 tons of batteries each year. The major four battery makers were all set to begin a national recycling program for single-use batteries until Rayovac backed out. Energizer, Duracell and Panasonic are all on board. So it’s up to all of us to tell Rayovac: America Recycles – Why Not Rayovac?
Reach out to Rayovac
Join us in marking America Recycles Day by sending messages to Rayovac and Staples and letting them know we care about recycling.
- Celebrate America Recycles day by liking and then posting on Rayovac’s Facebook page and Twitter account @rayovac or on Google+. Use #takeitbackrayovac and #recyclesday and spread the word through YOUR social media networks or through email.
- Don’t use social media so much? Call Rayovac’s CEO Dave Lumley at (608) 275-3340 ext. 54500.
Here are some ideas of what to tell Rayovac:
- America Recycles! Why not Rayovac?
- We won’t accept your double standards. It’s time to provide Americans with battery recycling like in Canada and Europe!
- Energizer, Duracell and Panasonic all support battery recycling. Why not Rayovac?
- Why do you tell your customers in Europe that throwing away batteries can harm the environment, but tell Americans that it’s safe to throw them away?
- Thousands of consumers have asked you to step up and offer real recycling for your products: when will you act?
Tell Staples: “We appreciate recycling leadership by Staples!”