Bev,
Thank you very much for speaking out on this issue.  I too am proud of
the work that many folks from many countries, including the US,
contributed to the CFC elimination work and other environmental issues.

Regards,

George

George M. Wenger, Reliability Engineer
Andrew Corporation
40 Technology Drive
Warren, NJ 07059
(908) 546-4531 or  (732) 309-8964 (Cell)


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bev Christian
Sent: Tuesday, July 26, 2005 8:30 AM
To: [log in to unmask]
Subject: Re: [LF] EPA Says No Harm To Environment From Landfilled WEEE


Mr. Speakman,
I would be careful saying things like you do in your second sentence.
Shoot, I think you should be careful saying things like your first
sentence too.  

In many ways the US is a LEADER in pollution prevention legislation. The
problem is that the US is so highly industrialized that it appears that
nothing is being done. Does that mean that enough is being done? No.
Does that mean we are in favour of pollution? Of course not. I have
three children (so much for ZPG in my case) and I hope that my
grandchildren, if there are any, have a decent world to live in.

Coming back to your first sentence: just because you read and hear
things that you do not like does not mean that they aren't true.  And
just because evidence is presented that flies in the face of parts of,
say RoHS for example, does not mean we are rapacious industrialists.  I
personally take offence that you would consider me "in the pocket of
protectionist US manufacturers" for a number of reasons:
1) I am not an American, nor live in that great but flawed country (as
all are)
2) The company I work for is about number five on my list of allegiances
which include God, country, community and family first.
3) Many of the people you are disparaging have good environmental
records. Personally I am very proud of the work I have done for Nortel
and for the UN in helping to get rid of fluorochlorocarbons. Bev
Christian Research In Motion CANADA

Opinions expressed here are my own and do not necessarily represent
those of the company that I work for.

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Speakman, Jim
Sent: July 26, 2005 3:17 AM
To: [log in to unmask]
Subject: Re: [LF] EPA Says No Harm To Environment From Landfilled WEEE

I think that we are all very well aware of the cavalier approach of the
US to the effects of pollution.  Most of the 'evidence' refuting claims
of damage caused to the environment by the polluting effects of
substances being presented by those in the pocket of protectionist US
manufacturers.

My $0.02 worth.



-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Davy, Gordon
Sent: Monday, July 25, 2005 20:37
To: [log in to unmask]
Subject: [LF] EPA Says No Harm To Environment From Landfilled WEEE


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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