Gordon,
Yes, I question the numbers are well. If this were the case why is that
Nortel and Lucent could run reclamation businesses that actually made
money?
Bev
RIM


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Brian Ellis
Sent: July 26, 2005 3:24 AM
To: [log in to unmask]
Subject: Re: [LF] EPA Says No Harm To Environment From Landfilled WEEE

Gordon

Thanks for this confirmation of what we have always said.

However, I do take issue on the question of recycling electrical waste.
I agree that if you take a populated PCB, the solder, gold and copper
are about all that can be recycled. The gold has been recycled since
goodness-knows-when (when I was making bare PCBs in the 1960s, we sold
all the gold-plated scrap). Solder is easy to recycle thermally and
copper chemically. But e-waste includes things like motors (I bust my
e-waste record this year as I had an irrigation pump weighing 8 kg to
chuck out!). Now please don't tell me that a) the copper in the windings
and the squirrel cage, b) the magnetic alloys in the stator and rotor,
c) the bronze in the impellor and d) the cast iron in the frame are
worthless. Only the enamel on the wire is un-recyclable. If I were to
chuck out a complete TV, monitor, computer or hi-fi system, you cammot
tell me that, at least, the thermoplastics and steel chasses are
economically un-recyclable. If you do, I say you are talking through a
hole unconnected to your brain.

As for the economics of WEEE recycling, it is break-even or positive in
Europe, so why isn't it in the USA?

Sustainability is a much over-used word, nowadays. I prefer to introduce
the notion of stewardship. Stewardship over our limited natural
resources. This includes all metal ores and, above all, fossil fuels. We
shall probably reach global peak oil in this decade (if we haven't
already arrived there; let's see the gasoline touch $5/gallon this
winter for this to hit home). As supplies diminish, so the need to
recycle plastics will become ever-more imperative, if the US public
wishes to continue its polluting and wasteful use of over-sized cars for
another year or two. But everything requires the use of oil: do you
really think the tin is mined and transported to your favourite solder
manufacturer and then to you, without consuming oil and other fossil
fuels, as you continue to sweat or freeze because of climate change. The
economics are a secondary consideration (the economy is one big lie,
anyway). The fact is that we must promote the notion of stewardship
which includes minimal usage of resources and maximal recycling, even if
  the latter **appears** uneconomical at this moment. Just saving 1 kg
of low grade mild steel from a computer chassis will prevent the
emissions of 3 kg of SO2 and 30 kg of CO2 to produce virgin steel.
Saving 1 kg of plastics will allow you to run a SUV for another 4 km.
And I don't buy the notion of using landfills as "ore": the cost in fuel
and resources for sorting to mine them would be prohibitive: much better
to cut down on them NOW by recycling the recyclable while we can.

You say we cannot afford to recycle: I say we cannot afford not to. So
please reconsider.

Brian

PS This should be removed to EnviroNet, to which I am cc-ing with your
original post.

Davy, Gordon wrote:
> This is a long posting, but I hope subscribers will read it anyway. I
> have stated before that if there were evidence that waste electrical
and
> electronic equipment (WEEE or e-waste) harmed the environment, we
would
> have long since heard it. The environmental activists would surely let
> everyone know as soon as they found out. One of the activists'
strengths
> is communication. Instead they warn darkly of "risk" and of what might
> happen, inappropriately invoking the Precautionary Principle.
>
> EPA testimony. Now I have just learned that in testimony July 20 to
the
> US House Subcommittee on Environment and Hazardous Materials, Barry
> Breen, EPA deputy assistant administrator for solid waste and
emergency
> response, stated in response to a question that the EPA has not yet
> found a case where electronic waste in municipal landfills has harmed
> the environment. In fact, he not only stated that had they not found
> such a case, he stated they had looked and found evidence to the
> contrary.
>
> I learned this from the July 22 "Environment This Week", emailed by
the
> Environmental Issues Council of the Electronics Industry Alliance. The
> mailing included an attachment of an article from the Daily
Environment
> Report, issued by BNA, Inc., July 21. The article, starting on page
A-9,
> is titled "States Say Federal Action May Be Needed to Address Concerns
> over Electronic Waste". (BNA Inc. publishes news, analysis, and
> reference products related to legal and regulatory developments. For
> access to the Daily Access Report go to
> http://www.bna.com/products/ens/bder.htm. A subscription is required.)
> Incidentally, on June 28 the US Senate passed a bill to promote
> recycling of e-waste.
>
> Quoting from the BNA report, "Regarding municipal solid waste
landfills
> that accept such waste from households and small businesses, Breen
said
> EPA has found pH levels and leachate collection systems have kept
> contaminants from harming the environment. If a landfill leachate
> collection system were to fail, he said, the level of contaminants
would
> rise to twice the level of national safe drinking water standards.
> However, these contaminants would be rendered harmless by being
> diluted." I offer further comments on leaching below.
>
> Mr. Breen also provided some interesting numbers about the cost of
> recycling. The cost to recycle a desktop computer is about $15, while
> the value of materials recovered is between $1 and $2.50. He added EPA
> is watching "with great interest" what the European Union is doing
with
> e-waste, but "it would be premature to propose a rule." That means
that
> to subsidize the recycling of a desktop computer including government
> oversight, consumers will have to pay at least $15, and probably more
> than that.
>
> To my knowledge, Mr. Breen's testimony to the subcommittee is the
first
> public pronouncement by any public official anywhere in the world that
> there is no evidence that landfilled electronic waste harms the
> environment. Since it is unlikely to be widely reported in the press
(or
> at all by the activists), I'd like to at least notify the Leadfree
> forum, in hopes that at least some subscribers will question why they
> believe that government-coerced recycling of e-waste is a Good and
Noble
> Thing to Do and why they are willing to subsidize it and make others
> subsidize it, too.
>
> Given Mr. Breen's statement on the lack of evidence, one might hope
for
> the EPA to not support any recycling legislation, but the remainder of
> the report indicates that it is unlikely that the other people
> testifying in favor of the need for recycling will either change their
> minds or offer a rebuttal. They will simply act as if the testimony
had
> not been given, and the push for government-coerced recycling will
> proceed unabated.
>
> Lamentably and somewhat surprisingly, Mr. Breen seems not to have
fully
> understood the implications of his testimony. First of all, he offered
> the statement only in response to a question from an astute
legislator.
> (Has no other legislator ever thought to ask for the evidence that all
> this legislative activity is needed?) One wonders whether, if he
hadn't
> been asked, he would have volunteered the information.
>
> Also, he said that he did not know the dangers of contaminants from
> electronics in incinerators. One would hope that a person with his
> responsibility would have investigated such an important matter before
> going before the subcommittee, and would have had an answer to offer.
In
> fact, lead in an incinerator will oxidize, and even if it didn't, the
> vapor pressure of lead is too low at incinerator temperatures for any
> significant escape up the chimney.
>
> Finally, he referred to the need for manufacturers' product
stewardship.
> If a manufacturer's products do not damage the environment, then what
is
> the source of the claim that the manufacturer has to exercise
> stewardship? This notion of manufacturer stewardship has been invented
> and proclaimed by the environmental activists as if the need were so
> obvious as to require no further question. No doubt one could make the
> case if the disposed-of product really has been shown to harm the
> environment, but what is the basis when there is no harm?
>
> Better evidence. Actually, it should interest Mr. Breen (and the
> subscribers to this forum) to know that lead and other heavy metals do
> not leach from landfilled electronics, even as much as he reported.
Bev
> Christian, a forum contributor and with a Ph.D. in chemistry,
presented
> a paper recently in which he used the EPA TCLP procedure to measure
the
> concentrations of various metals as leached, again after exposure to
> substances that are plentiful in soil, and after exposure to actual
> soil.
>
> This is much more meaningful than just reporting the TCLP leachate
> concentrations, as the leaching agent does not in any way represent
even
> the worst case of a real land fill. The results show that the
> concentration of metals after exposure to land fill conditions is
> drastically reduced.
>
> Here is an excerpt from the final paragraph of Bev's conclusion (page
> 9):
>
> "Addition of carbonate had the most effect on iron. For the sulfide
> addition, the soluble ion concentrations are essentially cut to almost
> zero, except in the case of iron, where the concentration was 'only'
cut
> by more than a factor of 10. Topsoil also has a significant effect on
> the concentration of the cation concentrations tested, resulting in
much
> reduced amounts escaping capture in a column of soil... It would
appear
> that the possibility of significant amounts of heavy metals escaping
> from modern, well maintained landfills is quite low."
>
> I would revise the final sentence, which I think is too cautious for
the
> data presented, to read "These data indicate that it is highly
unlikely
> that a significant amount of heavy metals escapes from landfills."
>
> This fact, coupled with the low proportion of discarded electronic
> products in municipal solid waste (only about one percent), leads me
to
> the conclusion that there is no need for government control of how
> electronic products are disposed of. In particular, I see no
discernible
> benefit to society (other than recyclers) for the government to force
> people to pay for recycling of electronic products, and no need for
> organizations to promote the concept of "producer stewardship" for
such
> products.
>
> BFR source. On a related topic, there is also now evidence that the
> source of brominated flame retardants that have been found in people
is
> not from the electronic products they own, but from house dust. The
> finding of the source was by Dr. Miriam Diamond of the University of
> Toronto and was reported in a recent news article
>
http://www.rednova.com/news/science/166689/household_dust_is_main_source
> _of_flame_retardants_in_humans/.   The specific BFR studied was PBDEs
(a
> class restricted in the RoHS Directive). BFRs are added to textiles
and
> this would seem to be a much more likely source of the dust than
> electronic products.
>
> It is worth noting that of the three kinds of marketed PBDEs, penta-,
> octa-, and deca-, the first two have now been removed from the market
> and a multi-year study in Europe failed to find any adverse health
> effect for the latter. The RoHS directive prohibits use of the first
two
> and that the Technical Adaptation Committee is supposed to decide on
> whether to restrict the latter.
>
> Dr. Diamond favors "more action" (i.e., further legislative remedy) to
> remove PBDEs from household products, in spite of the commercial
> unavailability of the bad actors. The article offers no explanation
for
> why she favors doing this. I wrote to Dr. Diamond but did not receive
a
> reply.
>
> If you read the article, note the lack of any reference to the
> precautionary principle. The precautionary principle in this situation
> would discourage introduction of a substitute without its first having
> been thoroughly studied to ensure that the remedy wasn't worse than
the
> problem. Dr. Diamond appears entirely confident that it will be
possible
> to find "alternatives that are effective in reducing hazards related
to
> fires and that do not accumulate in the environment." People in the
> business of making flame retardants lack such assurance, and in the
news
> article Dr. Diamond does not offer any notion of how she arrived at
her
> belief.
>
> Note also Dr. Diamond's assurances that PBDEs do not get into people
> from drinking water. This suggests that there is no environmental
hazard
> from unrestricted landfilling of products containing any kind of
> brominated flame retardant. I offer below an excerpt of the news
> article.
>
> Excerpt:
>
> "Household dust is the main route of exposure to flame retardants for
> people ... followed by eating animal and dairy products, according to
a
> report in the July 15 issue of the American Chemical Society's journal
> Environmental Science & Technology. Until this study, which is based
on
> a computer model developed by Canadian researchers, scientists have
been
> unsure exactly how people are being exposed...
>
> "Little is known about the specific toxic effects of brominated flame
> retardants, but some researchers say that the increasing presence of
the
> compounds in human tissue is cause for concern because they have been
> associated with cancer and other health problems in animal studies.
>
> "'Our work is good news and bad news,' says the study's lead author,
> Miriam Diamond, Ph.D., an environmental chemist at the University of
> Toronto. 'Good news because we've identified the main route of
exposure
> to PBDEs - house dust; bad news because we need more action to remove
> PBDEs from household products and replace them with alternatives that
> are effective in reducing hazards related to fires and that do not
> accumulate in the environment.'
>
> "PBDEs are released into the environment at their manufacturing
sources
> and also through everyday product wear and tear, which is the presumed
> source of the chemicals in house dust, according to Diamond. Asked if
> drinking water could be a possible source, Diamond said: 'No, it's not
a
> significant route of exposure.'...
>
> "Officials in the United States and Canada are still debating the fate
> of flame retardants, although the main U.S. manufacturer has
> discontinued production of two types of PBDEs - the penta and octa
> formulations - as part of a voluntary agreement with the U.S.
> Environmental Protection Agency."
>
>
>
> Gordon Davy
> Baltimore, MD
> [log in to unmask]
>
> 410-993-7399
>
>
>
>
>
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