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!”
Sustainability, Intelligence, & Safety chart the path from the Darkweb to the Lightweb
Review of Raffi Cavoukian’s book, “Lightweb Darkweb”
I just finished the excellent new book by Raffi (the popular children’s troubadour and author) entitled Lightweb Darkweb: Three Reasons to Reform Social Media Before It Re-Forms Us. I found this book to be inspired and very relevant for anyone working in technology, who’s thinking about the role of technology in our culture, and/or who’s concerned about the impact of technology on our kids. (In fact, I used a yellow marker to highlight the “important parts” and there is a whole lotta yellow in my book now!)
Lightweb Darkweb is a 21st century manifesto and call to action that presents critical information about our Internet culture in a vibrant and clear manner. While the internet and social media have made amazing things possible and accessible (the Lightweb), they also have a profound downside (the Darkweb), particularly for kids, that we must address.
The book is built around three compelling and urgent reasons to reform social media and issues a resounding call for a thorough “mid-course correction” before it is too late.
Reason 1: Safety
Raffi points out that social media (as well as the internet) were not designed for children, which is why we need to protect them from on-line predators (including bullies as well as advertisers). He takes on Mark Zuckerberg directly for wanting to market Facebook to kids. In the words of Jim Steyer of Commom Sense Media:
“What Facebook is proposing is similar to the strategies used by Big Tobacco in appealing to young people—try to hook kids early, build your brand, and you have a customer for life…..”
“Luring younger and younger kids into using FB without any indication it would be good for them is a brazen attempt to increase FB’s profitability. Is this not using the young for your corporate ends? Is this not violating childhood innocence for advertising profits? Is FB turning into a platform for colonizing the child psyche and spirit?”
Instead, he asserts, we need “privacy by design.” Also, Raffi brings to light the latest research on electromagnetic fields and radiofrequency radiation, pointing out the dangers, especially for young children.
Reason 2: Intelligence
“A vast sociological experiment is under way” that is teaching kids to value “artificial reality” over actual reality and real time play (and nature!).
“There are many signs of unhealthy culture in a civilization that currently seems stuck in short-termism, like a juvenile refusing to grow up, needing intervention. One clear sign is a predatory commercial culture and its willful exploitation of the young. Culture as bully. It’s our duty to resist it, to change it, to orient societal priorities towards life-affirming values and to oppose life-destroying practices. Resistance to unhealthy culture is not an option, it’s our duty.” (Emphasis mine.)
I know that things were difficult enough monitoring TV when my wife and I were raising our kids – it is now WAY more difficult with the emergence of social media. And it not just a dilemma for parents – teachers are also under heavy pressure – and Raffi speaks to them directly. He reminds us that the moral imperative is “first do no harm” and reminds us that “there is no app for wisdom – If you’re not grounded in the real world, if you can’t face the complexity of being fully human, how can you possibly thrive in navigating virtuality—or even tell the difference?”
Reason 3: Sustainability
The third pillar is the ecology of InfoTech: its manufacture, marketing and life cycle. This is what brings Social Media “to our fingertips….It’s not just about conserving the life-giving qualities of air, water and soil. It’s about a way of living ethically, a code of conduct for our relations with the Earth, with each other and with the future.”
He shines a bright light on the hidden hazards throughout the life cycle of electronics production which fuels our addiction to our gadgets and social media: “all our high-tech gadgets come from a very dirty industry in which rich nations extract the good stuff from the earth—and leave poor countries to clean up the mess.” Our reliance on “cheaply priced goods… have a big ecological footprint” all around the world. He correctly notes that none of us would like to see our own children working 12 hour days around hazardous chemicals to turn out “shiny-tech devices”, and that none of us wants to be on the receiving end of the tons of e-waste generated by planned obsolescence and our throw-away culture. He quotes from “The story of electronics” and “Challenging the chip: Labor rights and environmental justice in the global electronics industry”:
“Challenging the Chip is about challenging the industry to use its incredible ingenuity to dazzle the world all over again with cleaner, greener technologies, products, and components that are free of toxics, easy to recycle, and produced without harm to those manufacturing, assembling, and disassembling them…. the planned obsolescence of electronic devices, which become outdated very quickly, virtually rules out repairing or upgrading existing ones, and that forces consumers to buy new devices and throw out the old. The rapid pace of change is a real double-edged sword because new chemicals are being incorporated before adequate health testing is done, and we are also consuming faster than we can recycle….. An industry that’s been able to put thousands of songs, photos, and videos on a tiny chip has the capacity to pave the way towards a sustainable future.”
In conclusion, Raffi calls out industry leaders to accept responsibility for what they have created, to overcome their “tech hubris”, and to start investing some of their vast wealth into creating solutions:
”What if Bill Gates were to have an epiphany, realizing that the future health of his family—and indeed the global human family— depends on the deep greening of InfoTech? What if he were to commit himself to the thorough detoxification of the electronics industry by bringing his influence to bear on leaders in InfoTech and beyond?
What if he and other industry leaders were to publicly declare that InfoTech must prioritize the next generation of children the way it currently prioritizes the next generation of chips? What a lasting legacy that would be!”
The “Lightweb” needs to be guided by the principles of “benign by design” and Raffi cites leading sustainability thinkers and practitioners. He cites at length the “Vision for sustainable electronics” being developed by the Electronics TakeBack Coalition (of which I am the Chair), which envisions a future world where: materials and processes cause no harm; activities enrich communities; natural resources are protected; inputs and outputs of the manufacturing process are sustainable; working conditions are safe and healthy; and new business models prioritize sustainability and embrace lifecycle goals. In order to navigate this new path to sustainability, Raffi invites us all to participate in creating the new “Lightweb”.
Thank goodness for Raffi and hallelujah for “Lightweb Darkweb” – this new book is a beacon of light to lead us out of the current wilderness of the Dark Web and into a sustainable future. Citing Gandhi, he points us to a future where everyone has enough for their needs (but not their greed. Sometime it takes a troubadour to show us which way the wind is blowing.
Ted Smith has worked to promote sustainable electronics for over 30 years, as founder of Silicon Valley Toxics Coalition, Chair of the Electronics TakeBack Coalition, and Coordinator of the International Campaign for Responsible Technology. He is co-author and co-editor of “Challenging the chip” and lives in San Jose, California, which calls itself the “Capitol of Silicon Valley”.
Today we are releasing our first Report Card on the electronics retailers and their programs (or lack thereof) to help us recycle our old electronics. Staples, Best Buy, and Office Depot got the highest marks, as all three have robust programs that let consumers bring our items back to their stores for recycling.
But we gave F’s to nine of the 16 retailers we reviewed for having no real program. This includes retail giants like Walmart, Sams Club, Amazon, and Costco.
Another four, including Target and Radio Shack, got Ds for having limited programs.
Office Max was somewhere in the middle, mostly requiring people to mail products back, but notably taking printers and laptops back at their stores for recycling.
Retailers need to do their part
It’s time for these retailers to step up and start taking some responsibility for their role in the e-waste problem. They are selling us billions of dollars in electronics, but most are doing nothing to help us recycle them.
Walmart sold over $20 billion in electronics in the U.S. in 2012. They have 3742 stores, in all 50 states. Millions of people are buying their electronics there. Imagine if these were also recycling collection centers, that would be a big boost to the current e-waste collection infrastructure, especially in states with no e-waste recycling law.
Many of the retailers, including Walmart, tout their trade in programs, where you can mail back used items and get store credit. But the first problem is that they only take the small stuff that they can make money from (phones, tablets, cameras, etc.) and they don’t take the low value stuff that people really need help recycling – TVs, monitors, printers, VCRs, DVD players and other stuff you plug into your TV. And second, these are mail back programs. Most people won’t mail back anything but the very smallest stuff like phones. So it’s not surprising that these companies won’t disclose the volumes coming back from their mail-back trade in programs. It can’t be much. Retailers need to do what Best Buy, Staples, and Office Depot have done, and use their stores as e-waste collection centers. It should be just as easy for us to recycle our old stuff as it is to buy the new stuff.
The EPA released new figures recently that show that our recycling rates have increased, but we are still only recycling about 25% of the electronics that people are getting rid of. The rest is still going into the trash. The retailers are in an excellent position to help here, since that’s where we are buying most of these products.
We’d like to see the retailers partner with some of the manufacturers, particularly the TV companies, who always struggle to create collection opportunities for their recycling programs.
But we don’t just want to focus on the brick and mortar retailers. The online guys also need to step up. Amazon is the number #3 electronics retailer, selling $19 billion in electronics last year. True, it’s a more difficult proposition for them, since they don’t have stores. But Amazon has figured out how to set up a whole network of locker delivery locations, by partnering with various other retailers, including Staples, Rite Aid, Ace Hardware, and Seven Eleven. They could do the same kind of partnering to help their customers recycle their old electronics.
As consumers, we should give our business to the retailers who are doing the right thing, and helping us recycle. Why should we support the laggards, who are sitting on the sidelines and letting Best Buy, Staples, and Office Depot do all the work?
New figures just released by the EPA show that the U.S. generated 3.41 million tons of e-waste in 2011, up from 3.32 million tons in 2010. We recovered 850,000 tons, or almost 25% of that for recycling, up from 19.6% in 2010. But in the report, the EPA cautions that this apparent increase in the recycling rate is, “due primarily to better data, rather than a sudden growth in recycling.”
The figures come from “Municipal Solid Waste in the United States, 2011 Facts and Figures,” a report the EPA publishes annually waste from residential, commercial and institutional sources. The report shows that the e-waste recycling rate is considerably smaller than for some other product categories, summarized in the chart below, including auto batteries (96.2% recycling rate), major appliances (64.2%), and tires, (44.6%). Significantly, these are all product categories where the retailers play a major role in taking back the products, often when replacements are purchased.
The report does not represent all e-waste generation, but represents “selected consumer electronics” which include products such as TVs, VCRs, DVD players, video cameras, stereo systems, telephones, and computer equipment.
Comments from the Electronics TakeBack Coalition and the Basel Action Network
March 13, 2013. The International Trade Commission (ITC) has released a new report, “Used Electronic Products: An Examination of U.S. Exports.” It attempts to quantify the exports of used electronics from the U.S. to other countries, both developed countries (members of the OECD) and developing nations (non-OECD). While it fails to do this adequately for reasons discussed below, the report does contain important acknowledgments supporting the need for federal legislation, like the Responsible Electronics Recycling Act introduced in the 112th Congress. These are:
- Report says RERA would increase exports of commodity grade materials and result in an increase of U.S. based recycling and refurbishment activity. Any increase in U.S. based recycling or refurbishment work would certainly increase U.S. jobs.“However, (if RERA were enacted into law) the product mix (of exports) would likely change to reflect more tested and refurbished products and fewer end-of-life products (exported). Conversely, exports of commodity-grade material would likely increase, as more recycling activity would take place in the United States and UEP-derived commodities would be exported to manufacturing centers in non-OECD countries.” Page 6-8“UEP” refers to used electronic products and “commodity-grade material” is the separated material from electronics (metals, plastics, glass, etc.) that recyclers sell to the manufacturing supply chain.
- Report confirms that many recyclers don’t know what’s ultimately exported.The report appears to acknowledge the need for RERA by noting that as much as 41% of the respondents were “reasonably certain some portion of their UEP [used electronic products] output was later exported by another organization.” (Page xiii)
Both the fact that recyclers and other e-waste handlers are uncertain of the exact figure of exports and the exact destination of their exports confirms what proponents of RERA claim, that there is a strong likelihood that a significant portion of recycling in the US results in the export of unprocessed (and likely toxic) e-waste that is dumped abroad.
- More than half the export volumes reported goes to end uses that are often problematic.The ITC figures on page 5-2 show that more than half of the 1.5 billion pounds of exported e-waste goes to the kinds of end uses that can be quite problematic in developing nations. This includes exports of untested or nonworking products, products for disposal, recycling and disassembly, and an incredible 18% of the volume going to unknown purposes.) See our analysis of this information at the end of this document.
Why survey methodology doesn’t, and can’t answer key questions
Unfortunately, the report doesn’t provide the kind of clear data that we need about e-waste exports. It completely fails to answer these key questions:
- How much of our total e-waste gets exported to developing countries?
- Does this report support or discredit the notion that much of the used electronics that get to recyclers actually gets exported to developing countries?
1. Most data are presented as dollar value of used products sold, not numbers of units or weight of products.
Presenting data in terms of dollar values sold doesn’t really shed much light on issues of actual volumes sold, and what types of equipment is sold, or its toxicity and subsequent environmental harm. For example, circuit boards (whole and shredded) represent 38% of the exports by value, but only 17% of the volume (by weight, which is how most reporting on e-waste collection is done). The reporting on sales volumes simple does not help answer any of the key questions. While the report does give the weight of the equipment exported, it doesn’t report the weight of the total amount of e-waste generated.
2. The report’s data shows double and triple counting of the same equipment. (Page 2-3)
This survey asks companies to report on sales of used electronics. The respondents include U.S. companies from all parts of the supply chain – collectors, disassemblers, processors, reuse firms, brokers, asset recovery firms, etc. So the report is capturing sales by the collectors as well as sales by their downstream vendors, even though some of these sales were for the same volumes. The report’s construction makes it is impossible to tell which specific volumes referred to in the report, were reported multiple times. Clearly, some were.
For example, a collector sells a specific quantity of laptops, say a truckload, to a reuse firm. The reuse company then resells the same laptops to a broker. The broker then sells the same laptops (in a consolidated shipment along with other laptops) to a purchaser in another country. Clearly, the sales numbers in the report may represent that same truckload of laptops at least three times. This double counting results in a very serious skewing of results.
The report even acknowledges this double counting on page 2-3, using the seemingly innocuous term “cumulative sales:”
“…The sales value presented here is likely greater than the value of UEP material collected within the United States, since it reflects the cumulative sales for organizations throughout the UEP supply chain.”
3. Overstated domestic sales, understated export sales.
Because of the double (triple) counting problem stated above, the total figures on domestic sales (as opposed to exported sales) will be overstated. The report respondents acknowledge this, explaining that as many as 41% of the respondents saying that they were “reasonably certain some portion of their UEP output was later exported by another organization.” (Page xiii) But that’s not even mentioned in the “Key Findings” section, which shows that domestic sales represent 93% of sales (by dollar value) and exports only 7%. This could lead a casual reader to conclude that only 7% of used electronics are exported, which is not at all what the report actually says.
4. Survey format unlikely to get honest answers on illegal exports.
The ITC survey results underreport the volumes of e-waste exports to developing nations. This would be true of any report based on a survey of exporters. Why is this so? Exporting e-waste from the U.S. to non-OECD countries is illegal under international law. This practice is considered to be trafficking in hazardous waste, and has become such a big global problem that INTERPOL , the international policing agency, has launched a considerable effort to crack down on these exports. Thus, given that the practice is treated as a criminal enterprise, it is highly unlikely that a survey will ever yield accurate honest data about those exports. Clearly, there is a strong disincentive for an exporter to admit to exporting untested, or non-working e-waste to developing nations, when this is considered international trafficking in hazardous waste. Why would a company admit this illegal activity, especially to an agency of the federal government?
The report offers hints at some of the serious shortcomings of the survey methodology:
a) The ITC report admits that “The survey could not determine whether U.S. exports of UEPs bound for recycling or disposal in 2011 were sent to [informal processing] facilities”, those “with little regard to health, safety, and the environment.” (page xviii)
b) The ITC report admits that the limitations of the survey methodology could not “capture ad hoc shipments of undeclared UEPs mixed in with exports of other items.” (page xviii)
c) Respondents to the ITC survey offered the view that they “did not know the intended final use of nearly 18 percent…of US exports of UEPs.” (Page xviii)
NGOs such as the Basel Action Network have tipped off news outlets and enforcement agencies around the world about illegal exports from the U.S. In December of last year, EPA enforcement and Homeland Security achieved a criminal conviction of a Denver area exporter who will likely face jail time.
In light of the obvious deficiency of the survey method, one has to ask, “Why do a survey?” The ITC is a well-respected, capable research institute. However, the ITC was compelled to primarily use a survey for this research, since the request from the U.S. Trade Representative asking for research on e-waste exports specifically requested a survey. Thus, the deficiencies of the report were already baked in by the USTR’s mandate that the ITC use the flawed methodology of a survey.
5. Small companies not part of the survey.
The survey did not include small companies of 10 employees or less. But many of the “collect and export” type companies are quite small. Their whole business model is built around collecting products, loading containers, and exporting them to developing countries, which requires very little staff. Similarly, some brokers are also quite small. This survey didn’t include these either. We are not suggesting that small companies in general are more likely to be exporters, but these are two types of small companies which are quite numerous, and are known to be common exporters of untested, nonworking equipment to developing countries. Omitting them from the survey means underreporting of their problematic activities.
Our analysis of data on weight of used electronics exported
This is our analysis of the data discussed above under 3, “More than half the export volumes reported goes to end uses that are often problematic.”
The table on page 5-2 shows “End uses of exported UEPs (Used Electronic Products). Perhaps this is the most concrete information presented, although it assumes that the exporter actually knows the actual end use at final destination, which the report authors admit that they don’t really always know. As noted earlier, the report explicitly states that Respondents to the ITC survey offered the view that they “did not know the intended final use of nearly 18 percent…of US exports of UEPs.” (Page xviii)
The table does not separate end uses in OECD vs Non OECD countries. But it does show that exports of tested working equipment, and materials for smelting is less than half of what gets exported.
It shows that the total reported exports are 757,721 tons of used products, or just over 1.5 billion pounds. If we assume that the Materials Processing category is going to OECD smelters, which discussion later in the report suggests) and that the resale of working equipment isn’t overstated, then that still leaves more than half of the volume, or 7.73 million pounds, destined for potentially problematic export uses.
|End Uses of Exported UEPs 2011||
|Materials Processing (smelting, refining, sorting)||
|While “sorting” could mean anything, let’s assume this category goes to OECD smelting|
|Resale of whole equipment without further processing (tested/working)||
|Likely overreported in a survey, but let’s assume this is OK|
|Total we assume is OK|
|Recycling or disassembly||
|Resale of whole equipment or parts needing further processing||
|Non working or untested|
|Elsewhere in the report (p 3-9, table 3.3) it says exports for disposal total 241,279 tons, not 5768. No explanation is given for this mismatch.|
|Almost 18% goes for UNKNOWN purposes|
|Subtotal that is of concern for problemmatic processing|