Tag Archives: electronics

Lessons from an E-Scrap Workshop

By Scott Cassel, Chief Executive Officer & Founder, Product Stewardship Institute

Several weeks ago, I ventured out to Indianapolis for the Indiana Recycling Coalition Conference to give a presentation on product stewardship and extended producer responsibility. I then headed over to another area of the conference center to participate in a panel as part of Indiana’s first E-cycle stakeholder meeting. In a room filled with dedicated solid waste managers, recyclers, environmentalists, and government officials, we took a look at Indiana’s current e-scrap recycling law to identify successes, challenges, and potential solutions.

Photo courtesy of Denise Szocka

Scott Cassel, Thom Davis, Katie Riley, and two representatives from Solid Waste Management Districts discuss the Indiana e-scrap recycling law. Photo courtesy of Denise Szocka.

Indiana’s electronics recycling law is an EPR law based on a “performance goal” system, meaning that manufacturers must collect a specific tonnage of e-scrap per year (i.e., their goal). In Indiana, manufacturers are responsible for collecting and recycling 60% of the total weight of video display devices that they sell. However, since the formula is based on sales of newer, light-weight electronics, and old bulky TVs are the heaviest and most common item collected, manufacturers reach their performance goals very quickly.

This has become a problem. When manufacturers have collected enough to meet their goal, they cut off payment to recyclers. Recyclers then stop accepting material from collection sites, or charge these sites a fee to take the material.

Photo courtesy of Denise Szocka

Four workshop attendees work together to identify problems and solutions.
Photo courtesy of Denise Szocka.

Once the basic problems were understood by the participants at the Indiana e-scrap workshop, they explored possible solutions. The conversation in that room was eerily similar to the stakeholder meetings held in New York and Illinois. Now that we have worked so hard at educating residents about the need to recycle electronics, we certainly don’t want to tell them that we can’t take what they bring us.

In the Indiana workshop, one of the potential solutions – raising performance goals – was suggested. In fact, both Illinois and Minnesota have passed updates to their laws just this year (which go into effect July 1, 2015), setting the performance goal at a specific fixed tonnage rather than at a percentage of yearly sales.

For a long-term, stable solution, however, changes should be made to the program structure. E-scrap programs with the highest collection rates – such as programs in Vermont, Oregon, Washington, and Maine – require manufacturers to meet convenience-based standards to ensure that a majority of residents have easy access to a collection site.

The panel and workgroup discussions at the Indiana e-scrap workshop were a great start to improving Indiana’s e-scrap law. These fixes won’t be easy to apply, and each state is having their own state-based discussions. At the same time, the Product Stewardship Institute is holding our own conversations with e-scrap program managers around the country to better understand the common issues they face so that we can help to instill greater stability in existing programs, and offer states with no e-scrap laws a roadmap for the future. Working together, we can come up with viable solutions that we hope will be implemented in years to come.

 

To read more about the different types of e-scrap programs and their results, check out the recent article in E-Scrap News, “Struggling State-by-State,” by PSI’s Resa Dimino.

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Failure to Launch: U.S. Good at Throwing Away the Gold

For the 11th year in a row, Massachusetts has failed to pass electronics EPR legislation. It is now 12 years since the Commonwealth became the first state in the country to ban the disposal of lead-bearing cathode ray tubes, sparking the electronics recycling industry in the U.S…and placing the financial burden to manage electronics on Massachusetts cities and towns. It was the classic ban without a plan. Unlike the stellar U.S. women gymnasts who earned Gold in London yesterday, our country fails miserably at passing legislation that will keep gold and other valuable materials out of our country’s landfills and incinerators.

What a waste. What a shame. To watch our great and mighty companies offshore jobs, complain about it being the only choice they have, but do little to create thousands of green jobs that are there for the asking if they would engage with PSI and other stakeholders to develop extended producer responsibility (EPR) laws and other strategies that meet their own interests.

The powerful corporate self interest that has blocked movement on product stewardship and EPR in the U.S. is the same one that unknowingly is weakening itself, just as the U.S. auto industry’s fight against fuel efficiency standards weakened itself, causing the need for a government bail-out.

I just finished yet another book that chronicles ways that U.S. companies and policy makers are failing to take actions that will strengthen our economy, instead resulting in the slow decline of U.S. economic power. Edward Luce’s Time to Start Thinking shows what the product stewardship movement experiences on a smaller scale – a failure to launch.  Look no further than the microcosm of the product stewardship field, where many unenlightened companies fight against policies that will save billions of dollars for U.S. taxpayers, reduce waste, and generate thousands of recycling jobs.

These companies operate under the guise of groups like the Product Management Alliance, which evaluates EPR laws by showing that the laws that they weaken actually don’t perform well. How enlightening! The powerful corporate self interest that has blocked movement on product stewardship and EPR in the U.S. is the same one that unknowingly is weakening itself, just as the U.S. auto industry’s fight against fuel efficiency standards weakened itself, causing the need for a government bail-out.

As I wake up this morning to yet another failed attempt to pass an e-waste bill in the all-Democratic Massachusetts Legislature (and with its Democratic Governor), I wonder what this failure is all about…was Dell so bent on passing a bill that ensured that any goals included would already be met before the law went into effect? Or was the House leadership frozen in political gridlock on matters far removed from the bill itself? It is clear that there was no consensus on the bill, but how can stakeholders be so far apart for so long that we cannot figure out a way to act in all of our own self interest?

Close your eyes…and envision a time when we in the U.S. really went for the gold…like those women Olympic gymnastic heroes of today. Rather than burying our gold in the ground and mining raw materials in an endless cycle of waste, we owe it to ourselves to find a way to break out of this malaise together.

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“EPR’s Broken Promises” — Bah Humbug!

Government is so easy to rail against. How great it is to lambast those faceless time-sucking bureaucrats that don’t care anything about Me. How fun to stomp around, spit into the wind, and swear about all that they do wrong.

In the latest edition of E-Scrap News (December 2011), the Director of Corporate Environmental Affairs for Sony Electronics, Doug Smith, kicked a lot of dust onto the EPR bandwagon. He waived his arms madly and decried all the failed promises and half-eaten logic of pointy-headed pension-brained cubicle lifers. But by the end of his article, entitled “EPR’s Broken Promises,” Doug was onto something. He was asking us all to consider the programs in Canada and Europe, which resulted in “rational laws” and “protected the current economic markets and developed fair market financing.” Doug is rightly concerned about how government policies can best accomplish laudable goals, as well as to encourage product design changes by individual producers managing their own products.

Sure, there is much you might disagree with in Doug’s article. The claim that “[EPR has] no influence on product design” is as unsubstantiated as the definitive statement that it does have influence. Nor does the article fully explore that there are many other reasons why government pursues EPR laws – among them fairness to taxpayers, lowering government costs, environmental benefits, and recycling jobs. It also does not mention that many of the problems with the current laws were caused by electronics manufacturers failing to agree among themselves about what is best policy. Also, the statement that EPR is a “hidden tax” mixes up what is paid for by taxes (most government programs) and what is a consumer product fee (EPR). And the “regressive ripple effect of cost internalization” is a real mind bender. Oh, and my favorite – that no EPR electronics laws except CA’s ARF can claim to create jobs because there is no way to ensure that the jobs stay in the state.

But all the hand waving aside, Doug is pointing out the real need to take an honest assessment of the 25 U.S. EPR electronics laws. Which work, and which don’t, and why? What can we learn from laws in other countries? How have these laws performed relative to lowering costs, saving governments money, increasing recycling, creating jobs, and creating a level playing field? What are the policy best practices, and should these be woven into a new federal law that covers all the states?

Emotions can often run high with EPR. After all, the movement has created a paradigm shift of tectonic proportions that has changed the dynamic of how waste in the U.S. and globally is managed. For electronics EPR in the U.S., it is time to step back and assess the situation in a balanced manner – with all the stakeholders at the table.

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Why We Need Regulation for Fair and Effective Stewardship Programs and Why Voluntary Systems are not the Answer

Last month, as the Product Stewardship Institute celebrated its 10th Anniversary at our national forum, a new coalition of manufacturers seeking voluntary programs announced its creation. The Product Management Alliance (PMA) launched a press release stating that it seeks to “…support voluntary market-based extended producer responsibility efforts and voluntary incentives for increased recovery and sustainable product and package design.” PMA is comprised of manufacturers of carpet, electronics, toys, paper, packaging and transportation materials, mattresses, plastics, personal goods, and pharmaceuticals. But while voluntary programs have a definite role in reducing the health and environmental impact from consumer products, they are no substitute for balanced regulation, which is often a better way to foster innovative market-based solutions.

One good place to start is with the facts. Voluntary, market-based approaches will result in high collection rates only when a product has value at the end of its useful life greater than the cost to collect and transport that product to a secondary market. For example, many retailers collect toner cartridges because they can refill and sell them at a profit. No regulations are needed because the value of the used cartridge is greater than the cost to collect, transport, refurbish, and resell the refurbished cartridge. Retailers have the incentive to heavily market the return of those cartridges. In another example, a car battery left on the curbside will magically disappear because some enterprising scrap dealer will always pick it up and bring it to market for the value of the lead. Unfortunately, though, the cost to properly manage many other consumer products – including carpet, mattresses, electronics, toys, and all the other products whose manufacturers have formed the Product Management Alliance – is much greater than the market value of the used product.

After nine years and a signed agreement, the carpet industry’s best efforts to put in place a voluntary collection and recycling system has resulted in the recycling of only 4.5 percent of all the carpet available for recycling in 2010. The rest of that carpet material – more than 95 percent, or nearly 2.9 million tons – was disposed of in landfills and incinerators. Not only was this material wasted, but it causes operational problems at these disposal facilities, resulting in extra costs. The 13-year old voluntary industry thermostat recycling program reached only a 5 percent recycling rate before governments started to regulate. And the voluntary industry recycling program run by the rechargeable battery recycling industry for the past 17 years has posted only a 10-12 percent rate.

Wasted resources result in lost jobs and economic value. This is not a band wagon to hop on and emulate.

Don’t get me wrong. PSI supports voluntary programs under certain circumstances. Voluntary programs work well as a ramp up to regulated programs. They can grease the wheels so that, when a regulated system kicks in, the players know what they are supposed to do. These programs can also allow an industry leader to spark an innovative program. PSI worked with Staples in 2004 to develop the country’s first computer take-back program, which was piloted, then scaled nationally after two years. This voluntary program is available to everyone, and it resulted in innovative programs by others in the office supply sector, such as Office Depot and Office Max, as well as Best Buy. And voluntary programs can operate in areas where no laws, or weak laws, are in place.

But relying on manufacturers to voluntarily collect their products is like trusting that people will stop at intersections with no stop lights or signs…and no threat of enforcement.

Some people will have the sense to do it, but most will not. This is why the environmental movement was born nearly 50 years ago. It was because the market cannot police itself, resulting in environmental externalities in the form of pollution that impacts all of society. Do we really have to explain this concept all over again? Have we regressed this much?

Imagine a professional ballgame with minimal rules, no common goals, and no referee, where each player performs according to his own definition of success, and where there is no penalty for not playing. Like this imaginary game, voluntary product stewardship programs create a competitive advantage for those companies that will not act unless forced to do so. And, in every case, there will be a significant number of those companies. This reticence is unfair to those corporate leaders that know what is needed, have the ability to reach high performance, but get dragged down to the least common denominator.

The buzz among the product stewardship community is that the formation of the PMA is an indication that the product stewardship movement has gained steam, attention, and credibility. There is an interest in finding ways for voluntary industry initiatives to integrate with regulated programs. But there is also a concern that PMA is promoting voluntary programs to block sensible laws that will require them to take greater responsibility, even if the results will be better for the common good. There are other concerns about voluntary programs. Since they rely on the good will of companies, they could be here today but gone tomorrow. And it is often hard to know how effective they are since program operations are often not transparent, and companies selectively report data.

For the past 30 or 40 years, there has been a creeping sense among some in politics that all government officials are inept bureaucrats tying companies in knots, preventing job growth, and wasting investment dollars for little benefit. To be sure, those officials exist. But most officials I know are interested in using their authority to create a level playing field for fair competition that will result in more recycling jobs from materials that previously polluted the environment. They want to set broad performance targets and allow companies the flexibility they need to innovate and reach the targets at minimum cost. That is the type of balanced regulation and progress we need.

Government product stewardship regulations will result in fair and effective systems. Voluntary actions will not.

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Uprooting Subsidies: The Next Frontier in Product Stewardship

Last month I was fortunate to have been asked to present at the Northeast Resource Recovery Association’s 30th anniversary conference. One of my assigned topics was “Product Stewardship in 30 years.” Initially, this task seemed daunting…until I realized that I could say almost anything since no one knows exactly what will and won’t happen 30 years from now.

As I combed through my litany of what-could-bes, I considered the notion that 10 years of U.S. product stewardship might have finally positioned us to reach far upstream to reduce product impacts, and set us on the path to true sustainability. I even went so far as to say that the current conservative Congressional winds might just open the door to the removal of subsidies underpinning product un-sustainability.

During the question-and-answer period, one of our friendly participants asked me if my cause for optimism was justified. After all, many conservative politicians don’t give a hoot about environmental protection if it means that industry and consumers must pay for added social and environmental protections. Yet members on both sides of the political firestorm are increasingly focused on eliminating subsidies (tax breaks) due to a panic-inducing budget deficit.

First on the chopping block are ethanol subsidies.

Some thirty years ago, when a confluence of circumstances pushed the concept of alternative fuels to the forefront of Congressional consciousness, those growing corn for use in ethanol production received handsome federal subsidies. No thoughtful lifecycle assessment determined if this industry was sustainable. And there was no widespread public debate on the various potential alternative fuel opportunities. But in the heartland there was a focused political interest feeding off homegrown corn that couldn’t be eaten. Age-old ag subsidies, totaling $30 billion over the next decade, are now under attack as anti-subsidy proponents point to biofuel mandates that preempt the need for ethanol subsidies.

The political equation is fraught with fretting, yet the slash-and-burn, subsidy-removing, equalizer sword that conservatives wield at the peril of losing the Iowa primary could effectively level the playing field for sustainable energy as well as sustainable products. And many appear eager to use it.

I am fully supportive of the strong backlash against subsidies. The Product Stewardship Institute’s main objective is to level the playing field for products. Focusing on a product’s end-of-life management is a huge task. But let’s face it, that movement started over 20 years ago in Europe and Canada, and spread to the U.S. 10 years ago. That movement is in full swing. The movement begging for attention relates to the unequal playing field created by subsidies, which causes truly “green” products to be at a competitive disadvantage to those products that only claim to be green, or products that cut consumer price tags but raise societal costs.

This is the next phase of the product stewardship movement.

One of PSI’s goals is to encourage consumers to choose products based on their environmental and social attributes. That is a huge endeavor, considering those attributes often fall behind in product effectiveness, price, and availability. We are still unable to thoroughly and accurately compare the environmental and social attributes of different products. PSI’s green washing webinar  highlighted the plethora of environmental claims, certification companies, and public confusion over which products are truly environmentally preferable.

But if we look behind this external curtain, we begin to understand that the product manufacturing system must be challenged. Mining subsidies (150 years old) give millions of dollars each year to companies that extract raw materials from the earth at a time when we are desperately trying to promote the use of recycled materials.  Additionally the lack of company requirements for clean-up operations has left 500,000 abandoned mines, polluted 40 percent of western watersheds, and racked up a bill estimated between $32 and $72 billion (not including currently operating mines). We know similar subsidies occur in other sectors like the timber and virgin paper production industry, which allows special tax rates costing taxpayers $440 million a year. Another recent PSI webinar, on mining subsidies, captured these excesses.

If we look closely, there are subsidies everywhere, particularly if that term encompasses society’s subsidization of companies that do not internalize the true costs of their products. And that is the heart of product stewardship. Our movement, across the entire product lifecycle, seeks to require companies to assume the full costs of making products. I do not want to subsidize corn growers for making ethanol, thermostat manufacturers for making sure their mercury thermostats get collected, mining companies for extracting gold to be used in electronics, or any company for costs that society must bear because of that company’s business decisions.

That is a long way of saying that, yes, I am optimistic that now is the time to sound the subsidy issue alarm, and to level the playing field for those  businesses truly seeking environmental and social equity. I have no illusions that those rallying for subsidies will stop, or that others will join the effort. But the time is ripe to bring these issues into greater focus and educate ourselves and the public about what we really mean by product sustainability.

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My Trip to Wal-Mart: In Search of Sustainability

Edit: visit PSI’s Flickr page to see some photos from the 6th Annual Walmart and Sam’s Club Sustainable Packaging Exposition.

Over the past few years, Wal-Mart has successfully shed its image of fueling America’s thirst for low-cost consumption to become a leader in the emerging field of sustainability. Recently, I had the opportunity to speak about product stewardship at Wal-Mart’s 6th Annual Sustainability Expo in Bentonville, Arkansas. My message was that companies have a unique responsibility to be stewards of their products across the entire lifecycle, and that government can be a good partner. While that message was embraced by many company leaders, I also ran into a tsunami of market-based mania that fears change and uncertain outcomes.

Bentonville is a mix between Rockwell-like farmland with horses and cattle roaming in fenced-in plains…and company row houses. The Expo was located at a hotel that became a Mecca for hundreds of Wal-Mart suppliers, each touting sustainability claims that were verified by PSI partner, EPI, which after six years of Expos, still found the need to correct the claims for two-thirds of the vendors prior to the show. Every commodity association was there – paper, aluminum, plastic, glass, metals. Every consumer packaged goods company was represented, like Colgate-Palmolive, Kraft, Unilever, and P&G. Companies were selling eco-packaging, defined in innumerable ways. And the Product Stewardship Institute was there, with our spiffy table-top display.

Coupled with the vendor booths were three morning presentations, one after the other, two at a time. The rest of the day was free to view the exhibits and mingle. I presented at one of the sessions (twice) and sat in on several of the others. Wal-Mart puts a tremendous amount of effort into defining sustainability for itself and its suppliers. Wal-Mart’s Scorecard compares suppliers on a range of sustainability criteria so that buyers can make decisions based on environmental factors as well as the usual price, quality, and other variables, although I did not hear anything about social criteria (child labor, worker issues, etc.) being measured. The presenters went into painstaking detail about how suppliers are to fill out their Scorecard. The room was packed, and people were paying close attention. I asked several suppliers what motivated them to make changes towards sustainability. “Because Wal-Mart’s asking us to do it,” was the reply.

Perhaps then it should be no surprise that some companies did not take kindly to being told they have a corporate responsibility in the form of product stewardship, and that there was a strong role for government. This is a crowd that runs on voluntary programs, that is motivated by the market, and wants to keep government about the size of a pinhead. They are motivated by cost savings from sustainability, and have not thought much about the environmental impacts of their products when consumers no longer want them.  I took the challenge, and told them about market failures, and about the four tons of mercury going into the environment each year from the disposal of thermostats despite a decade-old voluntary industry program. I made the usual case for jobs, economic value, environmental protection, and taxpayer savings. I described how PSI developed paint legislation jointly with the American Coatings Association, and how this has resulted in the expansion of the recycled paint manufacturing sector, just as legislation on electronics spurred huge growth in the electronics recycling sector years ago.

There was much positive response to what I discussed. However, I also learned that many companies are threatened by product stewardship. One senior executive of a pharmaceutical giant knew all about the Product Stewardship Institute (PSI), including our national dialogue on medical sharps two years ago. His company is a major manufacturer of insulin and uses medical sharps as a means of delivering its medications to patients. He said he did not participate in our sharps dialogue because his company was not prepared to state its position. He complained that the dialogue was not developing solutions for real patients and that we didn’t know what patients wanted (even though we had patient advocate groups, sharps manufacturers, and other pharmaceutical companies at the table). During PSI’s two-year dialogue on medical sharps, we sketched out a statewide pilot project for the collection of sharps through various methods so we could evaluate the costs and complexities of such a model system. Unfortunately, the time and expense of developing the background information, reaching solutions, and designing a pilot came up short because the few key pharmaceutical companies (like this guy’s company) that needed to make a commitment refused to participate. Now, two years later, after billions more medical sharps have been disposed of in the trash, and after more worker injuries and added medical costs, I was told that this major company is working on an industry voluntary solution. He indicated he didn’t want any help.

Later, I saw a colleague from the American Chemistry Council and we talked about local government plastic bag bans and taxes, and how the Illinois legislation that requires producers to pay for recycling programs might be an interesting model, one that ACC and local governments in Illinois support. I then talked with one of ACC’s members and a founding member of AMERIPEN, the new lobbying group for consumer packaged goods companies. This person had attended my session, objected to EPR for packaging, objected to my slide on the benefits of EPR, and saw plastic bag bans as EPR which, by the way, she objects to.

All in all, I came away very impressed with Wal-Mart’s ability to motivate companies with the shear force of market optimism, its ability to stay on message with so many dedicated senior staff, and the results they have achieved. I also came away knowing that many companies and individuals shut down their communication because of fear about changes that product stewardship might bring. These people stop progress for themselves, their companies, and the social good. They are indicative of companies that will find themselves at the back of the pack in making the changes they need to stay competitive. They are risky investments.

I do not expect full agreement with the product stewardship message. But if a problem exists, such as waste, environmental externalities, pollution, lost jobs, and unnecessary costs, we need to put our heads together to come up with the answers. Company representatives that want government to wait until their company has an iron-clad position will only harden opposition to a joint solution.

As always, the Product Stewardship Institute is ready for discussion. We are ready to change our understanding of issues…because that is what happens when people talk to one another. But when problems persist, or if companies bury their heads, don’t expect PSI to stand by idly waiting for companies to finally decide they are ready. Where is the corporate responsibility in that? Where is the individual responsibility and personal commitment needed to take care of problems that products cause? If you work for a company and you don’t act now, try explaining that to your grandchildren.

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It’s Dark Down There: More Reasons to Recycle

Below is a blog post by Tom Rhoads, Executive Director of the Onondaga County Resource Recovery Agency in New York State in preparation for the PSI Networking Webinar, “Promoting the Extraction of Virgin Materials: How Subsidies Impact Product Sustainability,” on Wednesday, June 15th (2:00-3:30 p.m. EST). Please join us for the dialogue.

We can never get too many good news stories in this day and age. The Chilean miners’ rescue is certain to be one of the top stories of the year for 2010. I was born in a mine town, and although I never spent a full day working underground, I have toured several deep mines. The darkness is absolute when the lights go off. You literally cannot see your hand in front of your face. To be trapped thousands of feet underground is, for me, incomprehensible. To carry any faith in rescue after days of no contact was marvelous and probably a genuine life saver.

I recently read that these miners were harvesting copper ore that was less than one percent copper. Copper is a common metal, but its value has risen enough to drive men 2,300 feet below the earth’s surface. In previous accidents at this very same mine, men died for ore with one percent copper.

Many other metals and minerals are hotly pursued across the globe. Mines in remote Canada and Indonesia have become targets of billion dollar investment takeovers. China made recent world news and sent ripples down economic spines when it declared a suspension to the export of so-called rare earth minerals (those needed in everyday electronics, communication devices, and high-tech batteries and magnets common to many tools and most high-efficiency transportation.)

Can you guess where I am headed? In the United States, only about 60 percent of the U.S. population even has access to basic curbside recycling for containers and printed materials. (USEPA, 2008). In New York, I travel through several areas that offer no curbside recycling for packages, containers, and printed materials. Zero recycling. You see, recycling and recycling infrastructure have a cost. That cost is in addition to the cost of trash disposal. The regional agency I work for, the Onondaga County Resource Recovery Agency (OCRRA), uses the revenues we earn from trash disposal and recovered energy from the trash to pay for the entire program. OCRRA’s disposal fee is more than the cost of landfill disposal, but OCRRA’s tipping fee covers the costs and benefits of Household Hazardous Waste Events, recycling infrastructure, battery collections, free recycling assistance and supplies for businesses, Earth Day Litter Clean-Up, OCRRA’s newsletter, and much, much, more. Even the curbside blue bin for recyclables is paid for with the trash disposal tipping fee. The cost of these programs puts pressure on OCRRA’s tipping fee and the resources of many other local governments providing similar programs. And as we continue to reduce the amount of trash through waste reduction and recycling programs, OCRRA (like many other local governments) is actually penalized for its recycling efforts with reduced revenue in its primary funding source – trash disposal fees.

We constantly reflect on how to pay for waste reduction and recycling programs. But there is a better question to consider: what does it cost us not to recycle? When we send miners into remote and deadly environments, because it costs a little more up front to develop recycling infrastructure, is that really the way to keep score? If China has a lock on minerals needed for the next generation of economic growth or energy-efficient technology, can our children (and their children) really afford us tossing away cell phones, batteries, or old electronics that are far richer in mineral content than ore from a mine?

I hope you agree that these and other similar questions need to be asked when we discuss the cost to recycle, or how to pay for a system that places a priority on reduction, reuse, recycling, and recovery before landfilling.  Extended Producer Responsibility laws for e-waste have been tremendous vehicles to fund e-waste recycling infrastructure across the U.S. EPR strategies also have worked in Canada and Europe for other recyclables as well – including packaging and printed materials.

The faith of the Chilean miners to be rescued was probably their life saver. Faith in rescue, leadership during the crisis, oh yeah – and a $20,000,000 rescue effort watched by the world for 69 days; those were the story lines in Chile in 2010. Perhaps we can also consider that product stewardship by the manufacturer (thereby better engaging the consumer) for waste reduction and recycling is the form of leadership needed to avoid another crisis-making headline in the future.

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Recycling and Product Stewardship – What Wisconsin’s Governor Really Needs

An amazing thing is taking place in Wisconsin. Not only is Governor Scott Walker attacking unions, but he has tried to eliminate municipal recycling by getting rid of the requirement for local governments to run recycling programs and all state funding for them. He has done so while showing no understanding of its ramifications. A serious public backlash has included both Republican and Democratic legislators, and the Governor’s plan might well be thwarted. But perhaps we should take a closer look at what is taking place in Wisconsin. We see overwhelming public support for recycling, but a Governor who does not want taxes to pay for it. This sounds an awful lot like product stewardship to me.

During these lean budget times, government agencies across the country have reduced staff, which threatens their ability to protect public health and the environment from the negative impacts of waste disposal. By shifting the responsibility to finance and manage recycling from taxpayer-funded government programs to manufacturers and consumers, we get the environmental protection benefits we seek, but we also free up billions of dollars that government agencies have paid to protect the public from product impacts. We also place the financial incentive for reducing waste impacts squarely with those who know best how to reduce them – the manufacturers.

Governor Walker has raised an interesting question – Why should government pay for recycling programs? On one hand, these programs provide a significant public benefit. They keep waste from filling landfills; reduce impacts from waste-to-energy plants; and often provide businesses with lower-cost materials for manufacturing new products. They also create more jobs than disposal. Recycling, in other words, creates business opportunities while also saving energy, reducing greenhouse gas impacts, and protecting the environment. And if cutting off state funding leads to more landfilling of materials, local governments will largely bear the increased costs for garbage disposal. There are no cost savings for a recyclable bottle, newspaper, or milk jug that goes into the trash. In fact, the cost for disposal in many Wisconsin communities exceeds the cost of recycling. So, if the Governor wants to pass recycling costs onto local governments, it could indeed result in a tax increase in many areas, particularly if the materials now going for recycling are disposed!

Recycling provides public benefits. But why should government pay the cost to reduce the impacts from private business operations? Aren’t we then subsidizing businesses for creating waste? And aren’t businesses passing onto government what should be their costs? What incentive does that give manufacturers to reduce the waste they create once consumers no longer need their products, along with the associated cost it imposes on society? Not a whole lot.

So, while the Wisconsin Legislature should restore funds for recycling, it should also heed the Governor’s impulse to reduce taxes and develop a comprehensive state product stewardship plan. Wisconsin’s electronics law, passed in 2009, is a good first step. But there are many products to go before we sleep. The Legislature should get cracking now on its plan.

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Sustainable Apparel and the Need for Global Standards



On March 1, the Sustainable Apparel Coalition launched a new voluntary initiative by leading companies such as Wal-Mart, J.C. Penney, Patagonia, and Timberland. According to the New York Times, the coalition seeks to develop “…a comprehensive database of the environmental impacts of every manufacturer, component, and process in apparel production, with the aim of using that information to eventually give every garment a sustainability score.”

This initiative marks a turning point for the apparel industry, and offers promise that consumers will be able to make more informed purchasing decisions. This effort is laudable on its own merits. However, in addition, these companies are opening the window to what they don’t know. And in so doing, it is bound to raise some interesting questions, ones that will likely lead to the need for global environmental and social standards for product manufacture. For years, U.S. companies have had to compete with cheaper labor in China, India, and other countries. But are they competing on labor costs and other criteria at the detriment of environmental and social impacts?

In fact, what do we know about the environmental and social impacts caused by manufacturing operations in developing countries? The answer is not much. We do know that many used electronics are shipped from well-meaning companies, government agencies, and non-profits in the U.S. to developing nations to be recycled. It all sounded so good…until the Basel Action Network informed us that many of these operations polluted rivers and sickened unprotected workers. It is likely that the Sustainable Apparel Coalition will find similar operations in which their members are unsuspecting enablers of poor environmental and social practices.  As the New York Times reports, Americans spent nearly $340 billion last year on clothing and shoes, nearly all of which was made in other countries. 

The New York Times article begins with an image of blue dye and other chemicals floating downriver from textile mills in China. An inside photo shows a fabric dyeing factory in Mumbai, India, that appears to provide little to no protection of the environment and workers. Our values, as Americans, are embedded in our laws. We would not want those same practices to take place on American soil. Those who uphold our country’s values for our own people should ensure that their actions are not enabling practices that cause harm to others in far-away places. We should not be exporting jobs to other countries if we are not also requiring that products we buy from companies operating in these countries be made using the same environmental and worker safety standards that we require of companies operating here in the U.S.

Companies participating in sustainable business practices know that you either pay now or pay more later…in the form of health care for sick or injured workers, cleanup of pollution, and replacement of poorly made products.  The Sustainable Apparel Coalition is off to a good start.

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Offering Responsible Electronics Recycling Practices For Everyone, Everywhere

Protecting vulnerable populations from environmental, health, and safety risks is a critical goal shared by many in the electronics recycling industry.  It is a cornerstone of the R2 Practices, one of the new certification standards for the electronics recycling industry.

Some have asked why, then, doesn’t R2 establish outright bans on exports of electronic scrap to developing countries and on the use of prison labor?

The answer has to do with economic opportunity.  The stakeholders that developed R2 designed a set of requirements that call for equal environmental, health and safety protections no matter the location or situation.  Importantly, the R2 requirements do so in a manner that does not curb the business opportunities of law-abiding, state-of-the-art companies and their workers in developing countries.  And, with respect to prison labor, they do so in a manner that does not diminish the vocational training opportunities of people that are incarcerated.

The R2 Practices

During the multi-stakeholder development of The Responsible Recycling “R2” Practices for use in Accredited Certification Programs for Electronics Recyclers, aka the “R2 Practices”, stakeholders addressed critically important issues relating to the environmental, health, safety (EHS), and security performance of electronics recyclers and their downstream vendors.  The comprehensive standard contains provisions for best practices in a number of operational areas including:  an EHS management system, downstream due diligence, adherence to legal requirements including those covering exports, and reuse and refurbishing activities.

The resulting document—the R2 Practices—serves as the basis for the R2 Certification Program.  Electronics recyclers can contract with one of a handful of registrars (certification bodies or CBs) to become certified to R2.  This rigorous, two-phase audit process requires the recycler to exhibit conformity to each of the R2 Practices’ many performance and management system requirements.

R2 and Exports of End-of-Life Electronics Equipment to Developing Countries

Developing countries can be home to both atrocious, and “state-of-the-art”, electronics recycling and refurbishing operations.  In these countries, as well as internationally, there is a desire to shift electronics recycling and refurbishing away from the former and into the latter types of operations.  This accomplishes environmental, health and safety goals while also promoting good jobs in some of the areas of the world most in need of economic opportunity.

To ensure exported electronic scrap ends up at state-of-the-art facilities, three key criteria need to be met.  First, shipments of exported electronic scrap must be sent and received in accordance with the laws of the exporting and importing countries.  Illegal shipments all too often end up causing serious harm to health and the environment in the worst of recycling and refurbishing operations.

Second, all receiving facilities must be evaluated on a regular basis to ensure that they are employing best technologies and practices. In Asia and other parts of the world, there are a number of state-of-the-art electronics recycling and refurbishing facilities that rival those in the U.S. in terms of technology and materials management.

Third, all equipment must be accurately characterized on the shipping manifest.  Too often, e-scrap exports are characterized as “reusable” to avoid the added scrutiny and legal requirements that apply to “waste”.  This creates a loophole which can allow scrap to be inappropriately sent to a facility that is not capable of safely handling it.

R2 effectively addresses each of these criteria.  It prohibits the shipment of end-of-life electronic equipment containing toxic materials to developing countries unless the shipment is legal under the laws of both the exporting and importing countries. It requires that the receiving facility conforms to key R2 requirements and employs technologies appropriate for the materials it processes.  Furthermore, “reusable” electronics equipment containing toxic materials is subject to these same requirements unless it has been tested and its key functions are working properly.  Finally, all shipments must be accurately labeled.

Through these requirements, the stakeholders that developed R2 achieve the goal of protecting vulnerable populations while supporting legal, safe, environmentally-sustainable, economic development in developing countries.

R2 and Prison Labor

UNICOR (also known as Federal Prison Industries) maintains operations in a number of manufacturing industries, including:  textiles, office furniture, industrial products, commercial fleet asset services (commercial vehicle remanufacturing), electronics manufacturing and electronics recycling.  The company was established by Congress “to create a voluntary real-world work program to train federal inmates” – thereby helping them obtain employment upon release from prison.  To this end, the UNICOR electronics recycling program has been successful, as electronics recycling firms have experience hiring formerly incarcerated people from the UNICOR program.

A few years ago, some prisoners at UNICOR worked in unsafe settings in electronics recycling facilities.  Unfortunately, employees of less sophisticated recycling operations in the private sector have, and may continue to be,  exposed to similar dangers.  More recently, in December, 2009, The National Institute of Occupational Safety and Health issued a report that found no health problems linked to electronics recycling operations at the four UNICOR facilities it investigated.

Regarding the issue of prison labor, the stakeholder group that drafted the R2 Practices decided not to develop different requirements for different categories of workers.  Rather, the R2 Practices set forth extensive requirements covering on-site environmental, health, and safety; and they apply to all workers in a facility, be they employees, consultants, volunteers, or prisoners.  As a result, R2 does not prevent prisoners from safely learning new skills that will help them find employment upon their return to society.

The future of R2

R2 offers a practical and equitable approach to addressing the areas of exports and prison labor.  And as the industry continues to evolve, so too will the R2 Practices.  Similar to the spirit of the standards development process, R2 Solutions is inviting stakeholders from all industry sectors, including NGOs, to shape the future of the standard so it can continue to effectively address the needs and concerns of the industry.

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