Tag Archives: hazardous waste

A Product Stewardship Approach to “Flushable” Wipes?

By Dave Galvin, Hazardous Waste Program Manager at the King County Local Hazardous Waste Management Program

To flush or not to flush? This is a question many of us have faced over the years. Those who live with on-site septic systems are particularly sensitive to the quandary of what goes down the drain. Anything other than human waste and toilet paper (that is specifically made to break apart almost immediately) should be kept out of such systems, especially if there are small pumps involved along the way, which can easily clog. After you’ve had to clean a clogged pump or pipe by hand, your sensitivity to such matters goes up exponentially.

flLarge municipal wastewater systems, it turns out, have similar concerns. Items that don’t break down quickly do not belong in the sewer. Many such items end up jamming even industrial-scale pumps and other machinery, costing millions of dollars each year in the US for repairs. Other material, including small plastics and latex, don’t decompose in the normal sewage treatment process and end up contaminating the leftover solids, which, in many locales, are beneficially reused as a soil amendment known as a biosolid. This is analogous to finding plastic fruit stickers and bags in the municipal compost — “hard to handle” end-of-life management.

Some consumer products are labeled as “flushable,” but are they really? Items such as baby wipes and skin cleaners, paper towels, feminine care products, condoms, diapers, and even dental floss, are usually not designed to break apart immediately and are thus not intended to be flushed. Some wipes are marketed as “flushable” while others as “disposable”; they are made by the nonwoven fabric industry and are supposed to meet certain voluntary guidelines developed by this industry.

A group of wastewater and water quality associations is meeting with representatives of the nonwoven fabric industry (via a trade association known as the International Nonwovens and Disposables Association) to explore a “product stewardship approach.” What, you ask? Take-back of leftover wipes? No, let’s not go there. Instead, they have agreed to discuss the challenges that the wastewater agencies face and to tighten the requirements spelled out in the current Guidance Document for Assessing the Flushability of Nonwoven Disposable Products (third edition). A fourth edition is currently in the works.

Here is an instance where the product stewardship dialogue actually addresses design standards! How do you set criteria for flushability such that the product truly breaks down in ways that are compatible with on-site and municipal wastewater systems? How do you ensure that these products are truly acceptable to flush, that they are “biological nutrients” in McDonough and Braungart’s Cradle-to-Cradle sense? How do you establish clear and meaningful labeling and marketing standards for what is flushable and what is not? Interesting questions indeed, and a dialogue sure to blaze new territory in the product stewardship universe.

This discourse illustrates an expanded definition of product stewardship, one that covers the full lifecycle, including design and labeling decisions that affect end-of-life disposition. Who knows – maybe Scott Cassel should be invited to the “World of Wipes” international conference to expand the idea of what it means to affect sustainable product stewardship.

“Hard to handle” takes on new meaning where upstream meets downstream.

Dave Galvin is a Program Manager for the Hazardous Waste Management Unit in King County (Seattle, Washington), part of the multi-agency “Local Hazardous Waste Management Program in King County.” This program addresses household and small business hazardous wastes in the Seattle metropolitan area. Dave began working in this subject area in 1979 and was the one who coined the term “household hazardous waste.” He was the founding president of the North American Hazardous Materials Management Association and was previously the president of the Product Stewardship Institute’s Board of Directors. For additional information, Dave can be reached at Dave.Galvin@kingcounty.gov.

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Extended Producer Responsibility – The Gateway to Discomfort and The Path to Progress

I like being comfortable. Every Saturday, I rest. I make myself as comfortable as I can be. On the other days of the week, I make others uncomfortable. Not on purpose. But I suppose it’s the nature of our business…the EPR business. I think of ways to change how waste is managed in our country. And that can make people nervous and downright uncomfortable. The truth is that I am tired of disposing of my own garbage and watching other people’s garbage get tossed out. There are people starving around the world and using scraps to build their houses, and we in the U.S. are still throwing out tons of usable materials. This is a situation no one should be comfortable with. So I want to agitate. I want to change it. Many of you do too. But without holding someone responsible, who is also capable of creating lasting positive change, it will not happen. And that is where EPR comes in.

For years, government was given the responsibility to take care of its citizens. And it embraced that responsibility. Employees cleaned the streets from horse excrement, paved roads, and met the needs of citizens. Along the way, they also started to carry the burden of companies, which made more and more products that were shipped to the store or to the door, and that was the end of their corporate responsibility…unless someone got hurt directly from negligence on their part in the way the product was made or operated.

But now we know that products harm not only directly but indirectly. There are impacts all along a product’s lifecycle. Mining causes worker injuries, pollution, and blighted landscapes. Manufacture, transportation, use, recycling, and disposal all cause impacts. And the entity that can best change those impacts is the manufacturer that makes those products. Unfortunately, they are all too comfortable with how things are right now. After all, it’s tough in business. To survive is not easy. The successful companies have been able to maneuver through a host of obstacles. And who wants to have to engage in yet another challenge, which is what EPR represents? EPR is just one more obstacle to business survival, and one best avoided.

Those of us in the EPR business have gotten accustomed to making people feel uncomfortable. The first presentation I gave to paint industry representatives on paint recycling, well before PSI was created, was met with disdain. After my dinner-time presentation, a guy from California Paints stood up and literally mixed a bunch of liquids together into a can. He wanted to demonstrate how paint recycling was destined for contamination…how it could never be done right, how toxics would inevitably get mixed with good paint and create a hazardous waste of uncontrollable proportions. He sure showed me…15 years later, the recycled paint manufacturing industry is as strong as ever, and poised for exponential growth.

EPR advocates have learned to expect opposition. We are used to the push back. It is our job to make others uncomfortable and to rethink what they have always been doing for years. When my 21-year old daughter does this to me, I thank her for making me think…really think…about what I am doing and why.

It is time for manufacturers to really think about what they are doing and how EPR can help increase the supply of recycled materials, create jobs, and reduce pollution at reasonable cost. It is our responsibility as advocates to show how EPR can result in those benefits. But ultimately it will take those who are comfortable to become uncomfortable before those benefits are realized.

There is the old saying…no pain, no gain. You exercise and you feel better. It is time to start training for the EPR changes that are round the bend.

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Two Electronics Recycler Certification Programs?



Below is a blog post by Sarah Westervelt, the e-Waste Project Coordinator at the Basel Action Network (BAN) and the Recycling Coordinator for the Electronics TakeBack Coalition, in preparation for the PSI Networking Conference Call, “How to Choose a Reputable Recycler: Update on the R2 and e-Stewards Certification Programs,” on Thursday, November 18th (2:00-3:30 p.m. EST).  Sarah’s work includes administering the Electronic Recycler’s Pledge of True Stewardship, educating the public about the global toxics and legal issues associated with exporting e-waste, as well as highlighting the worst-case scenarios.  Sarah co-authored BAN exposés including films and reports documenting horrific “recycling” of the world’s e-waste in China and Nigeria.  Sarah has a Master’s Degree in Organizational Systems Renewal from Antioch University, and worked for years as a consultant in organizational development before joining the Basel Action Network in 2001.  Click here for more information on the PSI Networking Conference Calls.

For years, there has been little more than pilot programs, pledges and a great deal of concern about what electronics recyclers are actually doing with the e-waste they collect.  While federal regulations  exempt much of this waste stream, the relatively new electronics recycling industry has been plagued by unscrupulous companies that profit largely by exporting scrap or untested/non-working equipment to countries that cannot legally trade in hazardous waste with the US, as defined in a United Nations treaty called the Basel Convention.

© Basel Action Network 2008.

© Basel Action Network 2008.

As of this year there are not one, but two accredited certification programs for electronics recyclers in the US, both of which are recognized by the US EPA  – the e-Stewards Certification program and the Responsible Recycling (R2) Certification program.   The question is,  what are the differences, and which one of them will best serve your needs?  Having two programs requires some homework on the part of customers or officials.

To get to the bottom of this question, it is important to compare the standards themselves, as well as the rigor of the verification system (i.e. the certification bodies which certify that recyclers conform to a particular standard, and the accreditation bodies that oversee their work.)

Let’s start with comparing the verification systems.  Both R2 and e-Stewards certification programs utilize the ANSI-ASQ National Accreditation Board as their accreditation body.  ANAB is one of the top three accreditation bodies in the world, and is the largest, most respected in the United States.

Next, let’s look at the certification bodies (CBs) that are accredited by ANAB to certify to either R2 or the e-Stewards Standard.   Each of the programs has three certification bodies that are accredited to certify to their respective standards.  An important question is how rigorous and consistent the auditor training is for each program, with the goal of having a high level of confidence that the auditors across all the CBs consistently understand the standard they are auditing to and program requirements.   Without an owner for the standard or host organization until this fall, the R2 program has not had a sole auditor training program since its inception, resulting in a variety of auditor trainings for the different CBs.  The e-Stewards program requires that all auditors must successfully complete a 3-day training provided by SAI Global, one of the top professional training organizations.

Finally, and central to every certification program, are the standards that define requirements for the companies attaining certification.  The R2 Practice document, which was finalized without support from the environmental community, is 13 pages long, with no guidance document, but it comes with an audit checklist.  The e-Stewards Standard, created by the Basel Action Network in conjunction with leaders in the recycling and refurbishment industries, and supported by 70 organizations, is 49 pages long.  It has a 67 page companion guidance document, but no auditor check list.  Based on the shear length of the two standards, it is easy to understand that one spells out much more comprehensive requirements for the recyclers.

There are two basic types of requirements in each of the standards.  One set of requirements is for the environmental management system (EMS), which involves a Plan-Do-Check-Act system for identifying, documenting, and reducing the environmental impacts of the business operations.   The R2 Practices has one page of general requirements that an R2 recycler’s EMS must meet .  The e-Stewards Standard has the 8-page global standard for environmental management systems, called ISO 14001, imbedded in it, so that all certified e-Stewards are also certified to ISO 14001.

Within this framework of an EMS, both standards require some minimum performance requirements, which are the second basic type of requirements in these two standards.   Performance requirements are industry-specific restrictions of or prescriptions for certain activities.   Along with the EMS requirements, this is where the two standards differ dramatically.

The chart below summaries some of these differences:

Does the Standard…   R2 Practices e-Stewards Standard for the Responsible Recycling and Reuse of Electronics
…Allow toxic materials in solid waste landfills & incinerators? Yes.  If circumstances beyond the control of the R2 recycler disrupt its normal management of the toxic materials, it may utilize solid waste disposal facilities, to the extent allowed under applicable law.   No, as it was deemed inappropriate for heavy metals and other hazardous materials to be disposed of in solid waste disposal facilities.
…Ban the export of toxic materials to developing countries? No.  R2, in principle, calls for only allowing the export of  equipment and components containing ‘focus materials’ to countries that legally accept them, but does not ban them from rich to poorer countries. Yes.  Based on the international definitions found in the Basel Convention, toxic materials bound for recycling or disposal are not allowed to go from developed to developing countries, consistent with the Amendment to the Basel Convention, already ratified by 65 countries, including the European Union.
…Require accountability for toxics throughout final processing? Limited. Yes, with detailed performance requirements for downstream audits, documentation, and restrictions for initial and on-going accountability.
…Allow untested or non-working equipment to be exported to developing countries for refurbishment (which can transfer hazardous waste)? Yes. No.
…Have detailed minimum requirements for occupational health and safety? Left to the R2 recycler to determine. Yes, developed with a great deal of input from state occupational health and safety experts.
…Allows the shredding of mercury-containing devices? Yes, “if they are too small to remove safely at reasonable cost, and workers are protected…”, and if the mercury-containing materials are sent to licensed facilities that utilize technology designed to manage it. No.  There are no safe levels of mercury, and currently no shredders that can capture all mercury vapors.  Shredding mercury disperses it into the shredded mixed materials, the workplace, and the environment.
…Prohibit the use of prisoners to recycle toxic electronic waste? No. Yes.

While having two certification programs requires some due diligence, most people welcome the arrival of new mechanisms for holding an industry accountable for managing a toxic waste stream.

Check out the companion post to this blog piece by John Lingelbach of R2 Solutions.


© Basel Action Network 2008.

© Basel Action Network 2008.






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