Fiddling with Product Stewardship (as E-Waste Burns)

Product Takeback/ Stewardship advocates and laws have manufactured a System for recycling  which requires maintenance and stewardship.  The ship of Product Stewardship is seaworthy, but it's headed for an iceberg if the advocates are just focused on the next legal product and don't take responsibility for the takeback laws they already created.

Check the List, Below, of TV recycling company closures and failures.

The "Product Stewardship" movement needs maintenance... or at least some fiddling with.

When devices go obsolete Stewardship advocates make manufacturers "fix the problem".  But what's good for the goose, is good for the gander, right?

Something is broken in E-Waste Stewardship.

As I testified and wrote 5 years ago, electronics reuse markets are so complicated (compared to mattresses, paint, and alkalines) that "e-waste" was probably NOT the best product for wiser Product Stewardship Advocates to start off with.   Now, the list of problems in the electronics recycling infrastructure in "ewaste stewardship" states is growing bigger.   Primum non nocere - "first do no harm" - needs attention.

But that's water under the bridge.  We have these state "takeback" laws now, and a command and control system of accounting for residential TV recycling.

Take a look out the window, my friends.

Here is a brief (and incomplete) list of CRT Recycling Companies which have left the residential TV and computer recycling markets in the Northeast, some permanently. The squeeze of NOT reusing (liabilities in contracts banning exports), and subsequent glutting of CRT glass end-markets (prices better for buyers), has driven up costs, but there's no way to send a Price Revision.  Meanwhile, in NY, NJ and PA in particular, some OEMs reportedly met their "obligations" and left these recyclers, and others, to "pound sand".

My company is still around in part because of our good fortune losing our largest contract - Oyster Bay in NY Long Island, which we lost in 2012.   The OEMs had said they met their goals, and we thank our lucky stars that a competitor talked Oyster Bay into dropping us as a vendor (that competitor is now on the "casualty list" below - focusing on commercial electronics and out of the residential stewardship game).

Others were not so lucky... The Northeast Product Stewardship map has some big holes to fill...

  • 2TRG - Ohio Recycler that was part of EWSI Roll up.  EWSI failed to fulfill its financing obligations to Good Point Recycling after GPR invested significant accounting.
  • Creative Recycling* - Major service provider on East Coast (including NY, CT, NJ, PA), one of our biggest competitors in NY.
  • CRT Recycling (CRTR)* Brockton MA - was one of our largest competitors in MA and NH.
  • Eco International NY/PA* - This site was one of the oldest and most respected CRT glass processors in the Northeast.  They reportedly left the largest (12k tons) pile of CRT glass during their bankruptcy.
  • Ewaste Recyclers, LLC of Jaffrey, NH closed without finishing the recycling of CRTs they had accepted.
  • EWSI Geneva NY -  See 2TRG.  They affected us not only by being a competitor without a sustainable economic plan, but triggered enforcement in NY raising the costs of recycling.
  • MPC PA/MN* - One of our backup companies when we ran out of manufacturer obligation in NY, discovered with 2,500 tons unprocessed CRT glass in Philadelphia area.
  • North Coast and Kuusakoski did not go out of the residential TV recycling business, but gave up even trying to pay for CRT glass recycling, creating a huge controversy with dumping CRT glass on municipal landfills as "daily wind cover".
  • Sims Metal Recycling NY/NJ/Canada - Closed largest e-waste plants this year after $115M annual "write offs" for e-waste.
  • StoneCastle - Not a Northeast player, but contacted Good Point to ship dozens of trailers of CRT glass in 2012, 2013 (to Retroworks de Mexico).  We did not execute the PO based on our credit review, but this would have taken us down with them.
  • Waste Management Inc. closed its CRT dismantling facility in Springfield, Massachusetts, three years ago.
  • WeRecycle* CT/NY - The company went through a brief bankruptcy (shortly after taking over VT one-day events), was purchased by Hugo Neu Recycling, and then withdrew from residential recycling contracts.  Had been one of the largest CED recyclers in CT, NY, MA, RI.


This is probably over 50% of New England CRT capacity, down in flames (figuratively or literally), since the passage of Product Stewardship Legislation in the Northeast.

Some of this is the scrap metal and plastic market - not anyone's fault.  But the largest recyclers in the list failed while scrap prices were at an all time high...

For the past 12 months, we've lost $250,000 just on scrap prices.  The "high" is over.

True, the Product Stewardship laws did create a booming supply, and brought expansion and investment to the industry.  But now, prices for scrap have crashed, and there appears to be little way for large, single-payer contracts like Vermont's to make adjustments.






And it's not just circuit/wiring board.  Steel scrap prices have crashed.  Copper scrap prices have crashed.  Plastic scrap prices have crashed. The price of circuit boards has gone through the floor, following the lowest gold prices since the recession.  As the USA dollar gets stronger, even reuse markets are shrinking.

Good Point continues to meet all of its obligations, paying what is necessary to recycle the CRT glass, at smelters and new CRT furnaces.  But we can't love a business that doesn't love us back.  The cost of Certification (mandatory in Vermont) keeps going up, and the state keeps increasing its insurance requirements.  We need to keep paying our staff a living wage, and that wage should be changing as the unemployment rates fall.

Time for some leadership.

Environmental Anaphylaxis: Auto-immune Attacks by Environmentalists on Harmless Africans




Last week I was alerted to an editorial by Laura Seay and Alex de Waal (July 17)

This was via a tweet from AfricanSolarLLP, a boots-on-the-ground solar energy project coordinator based in Accra, Ghana, who (along with Alhassan Abdallah) has been bringing first-hand accounting of the Old Fadama / Agbogbloshie real estate evictions (vs. "Sodom and Gomorrah") via @Twitter.





The article (Q and A) addresses many of the cautions I've undertaken, and there's some heavy stuff to dish out to readers of de Tocqueville.  An increasing number of environmentalist intellectuals like myself, may remain ardent environmentalists, but still fear the "churchiness" of the environmental-regulatory complex.  This is also true of other "world savers", we can be ardently pro African while suspicious of what Peter Buffet called the Charitable Industrial Complex.  In fact, much of it could apply to Fair Trade Recycling, and is a reminder of the dangers in heroicizing our "geeks of color" and "hurricane bensons".

Making more people aware of an injustice by oversimplifying the problems and the remedies is Poster Child Policy.  Making sad photo-essays of orphans working in scrap yards, and representing those children to be "emblematic" or embodiment or archetypal of African importers, is wrong on the science, and leads to environmental malpractice.

The challenge is to neither write so densely that no one reads it, nor so simply that it sets people off with the equivalent of racial profiling.  Basel Action Network "simplified" the long and complicated Annex IX, B1110 rules on export for repair and refurbishment by telling virtually everyone that it meant "fully functional", creating a set of enforcement guidelines which Joe Benson eventually gave up and pled guilty to in return for a decreased sentence.  [NOTE: That is not "twice convicted of the same offense," the just-world-fallacy / panacea shared by CWIT].  But at the same time, we have to recognize that progress has been made in understanding the nuance of "ewaste exports", and I think I can report that arrests of other Africa Tech Sector geeks like Joe Benson are less likely.

The awareness of the misuse, and misapplication, of well-meaning guidelines should serve as a broader lesson for all environmental interventions.  First, do no harm.  Protection of the innocent takes precedence over the simplified profiling guidelines (what Emile Lindemiller of Interpol called "Proactive Enforcement" - get out there and accuse people before the crime has been committed, and less environmental harm will occur.

That's like giving snakebite kits to everyone and telling them to incise and suck out the venom, whether you know the snake was poison or not.

I'm happy to report that Interpol staff may not be electronic repair experts, but I'm reassured they can eventually see when their enforcement is being abused by interested parties.  Eventually, they will get it right.  What environmentalists need to learn is to take responsibility for our stewardship and environmental dumping enforcement "cures" before a proper diagnosis has been reached.

This is how the study of environmental health must learn the same lessons as the application of western medicine to promote human health.  It's ok for a doctor to make a mistake, a mistake is not malpractice.  It becomes malpractice when you have been provided information to correct your practice and don't follow it.  This is the pivot point.  We don't blame NGOs or Interpol for believing 80-90% of used computer purchases by Africa's techs were for "primitive burning" when they actually believed it, and were told so by the press.  Once the source of the statistics has been discredited (and we can safely say we are at that point), it is the way the agencies - International and Non-profit - comport themselves going forward which matters.


Review: Jacopo Ottaviani Documentary "E-waste Republic" Mystery Vault

The great news is that  -- compared to previous articles (via BBC, The Atlantic, The Guardian, NPR,  NY Times, Washington Post, Wired, etc.) -- the web documentary appearing yesterday on Al Jazeera and internazionale by young Italian reporters Jacopo Ottaviani and Isacco Chiaf, "E-waste Republic", is much more sophisticated.  It allows many other (English-speaking) voices to come forward and describe the nuance of a scrap problem in an African city.


This documentary is far ahead of the pack in documenting the complex pieces of the electronic reuse and scrap markets in Africa.   And they hit the nail on the head by stating that demolishing Agbogbloshie will make the problem worse.

Kudos to Ottaviani for interviewing second hand dealers and repair shops, and giving time to yours truly (on behalf of WR3A / Fair Trade Recycling).  They give author Adam Minter [whose own accounts of Agbogbloshie are frankly more factual] almost as much screen time as Mike Anane.  There are data and statistics, and the documentary stands apart from the lie that boycotting Africa's Geeks will somehow make wire burning juveniles "go away".  I thank and respect Ottaviani and Chiaf for taking the hours and hours to get a "whole story" perspective.

What the documentary fails to do, sadly, is to correct the proportion distortion. or the myth that import for repair is "illegal".  Like Kyle Wiens piece @Wired, Ottaviani recognizes the demolition of the slum is bad - but alsocontinues to make the story about westerners' stuff.  This continues the central conceit that Agbogbloshie's problems somehow revolve significantly around "imported e-waste".

The focus on e-waste exports in sea containers is the Mystery of Al Capone's vault, 29 years after.



[ postscript:  This was a tricky blog to write, as I respect Jacopo and Isacco and value the effort to interview #geeksofcolor and tell a nuanced account.  But it also perpetuates definitions of #ewaste that include reuse and repair, and false testimony about volumes and timelines of simply disposed waste, and honestly it does represent another example of photojournalism's need for exotic hooks. ]

Delayed Report on WR3A Investigation of Africa Tech Sector and Agbogbloshie


Please excuse the delay in publishing the promised report on our visit to Accra, Agbogbloshie, Mole, Tamale, and Tema in March and April, 2015.

We were nearly finished with a report, and expected to post it before end of the month of May.  However, four major developments occurred in the weeks immediately preceding the publication date.

  • Natural Disaster - A major flood in Accra, combined with an explosion at a gas station, killed 150 people.  During this disaster, no one was thinking about discarded appliances.
  • UNEP published a lazy, poorly reviewed report (ignoring most of the studies they cite from UNU), and worse, accompanied it with a false headline of "90% illegal" (which was contradicted by the contents of the study itself).   Mathematically, how can 90% of contents be illegal if only 1/3 of seized containers contain SOME illegal material?  What mattered were the photos - eight of Agbogbloshie.
  • CWIT and Interpol announced a meeting for June 24 and 25, featuring Jim Puckett of BAN and Mike Anane as speakers.   While we felt it was unlikely they would spring "new information", we were already delaying our report to address UNEP's "new information" and waiting seemed prudent.
  • AMA, a local Accra municipal association destroyed Agbbogbloshie, citing "floods" and "ewaste imports", AMA sent bulldozers to knock down the homes and businesses of tens of thousands of Agbogbloshie residents and workers.  It was the beginning of Ramadan, and #UNWorldRefugeeDay and rainy season... and the bulldozing to "dredge the waterway" occurred at the populated homes side of the slum, not the abandoned side of the waterway.  
From our "e-waste" prospective (not the evicted's), what's most important about the last point were a couple of hours of filmed interviews we have, with Ghana technicians and scrappers.  Some had told us, when I asked "why?" about the #ewastehoax of Agbogbloshie, that they believed it was part of a propaganda campaign to take their land.  

I reviewed the maps and it was definitely true that Agbogbloshie, described as the remote "outskirts" or "nearby cities like Accra" in Greenpeace and other NGO reports, is smack dab in the middle of the city, 9 minutes from the most luxurious hotels, less from major banks and government complexes.  But in the first draft of the report, I avoided mentioning it, as I thought it came across as rather paranoid.  Now, after the evictions and apparent razing of the scrap businesses, I have to  check that dismissal...

The entanglement of Western second hand goods export and urban planning in Ghana is complicated. In writing the report, we need to check our outrage, and report the facts.