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August 2001

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Subject:
From:
"Davy, Gordon" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Fri, 17 Aug 2001 08:42:53 -0400
Content-Type:
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In a recent posting relating to recycling of cars Brian Ellis dismisses the
quality of the reporting (in the item posted by Jack Crawford) as if to say
that the general public is unable to understand such matters. (The term that
comes to mind is "elitism.") He points out that car recycling is already
done in many countries and says "I'll ask you a question. If it costs $160
to recover most of the metal and plastic in a car for re-use, how much would
it cost to win and purify the equivalent amount of ore and petroleum, to
produce the same quantity of virgin materials?"
Let's be clear here. We're not dealing with graduate-level economic theory
or engineering. The question is not how much it costs to convert ore into
products, but how much extra it costs to recycle. If recycling pays for
itself, no EU bureaucrat is needed to write rules. The way that I interpret
the news report, the $160 is a consumer-supplied subsidy to cover the
difference between what it costs to recycle the car and what the recycler
can get for the parts. It seems that the reporter is not very curious to
determine why car recycling pays for itself in some places and costs so much
in others (how much does it cost to transport a truckload or trainload of
unwanted cars to a place where someone will pay for them?), nor the
connection between the metal bans and the imposition of the fee.
On the subject of California demanding that its citizens recycle CRTs, Brian
seems to have missed the point. He repeats the assertion of hypothetical
risk from lead in the glass of a CRT in a landfill, but ignores the facts
that the ground already has plenty of lead in it and ground water doesn't,
and that this isn't going to change anything, except, as Bev Christian point
out, subject recycling personnel to possible risk. (If the risk were real,
then California would still be dealing with a tiny piece of the problem it
while ignoring the rest. It is "straining out a gnat and swallowing a camel"
to use the words of Jesus.)
And who will believe that people might get poisoned by the "highly toxic
phosphors" on landfilled CRT screens? That I would call sheer fantasy. I
know that Brian knows enough chemistry to know better. Who comes up with
these things, anyway? People who decide what they want to make other people
do and then try to think of plausible (or frightening) reasons. This one
fails the snicker test.
Again, if recycling of CRTs pays for itself, no rules are needed. The
function of rules is to make people do what they otherwise might not. And
since there is no demonstrable (or even credible) risk from landfilling
CRTs, the decision should be based on economics, not rules. I think that the
general public can understand that.
I got a response to my posting from a representative of the Department of
Toxic Substances Control, and he graciously offered to discuss the matter by
phone. When I called him he explained some factors which the Fact Sheet
didn't make clear (to me, anyway).
Last January, the Department was approached by environmental groups and a
lobbying group called Californians Against Waste. The latter group, he
explained, is funded by recyclers. (I was unable to reach their web site,
but you can find out something about it, including the fact that it has over
20,000 members, at http://www.recycle.net/sites/rs190134.html. Somehow I had
overlooked the recyclers themselves as being a significant force for
promoting recycling - how naive!) These groups pointed out that because
CRT's fail the TCLP leach test prescribed by the US EPA and California's own
test (Waste Extraction Test), they are hazardous waste, and therefore their
disposal in landfills is a violation of EPA rules. The fact that the tests
have no predictive value is of course, from a legal point of view, entirely
irrelevant.
The rules that DTSC came up with were the least burdensome to citizens that
they could devise while still complying with all the rules that apply to
them. So it isn't a question of whether the DTSC rules make sense, but the
EPA rules that drive them. He said that EPA has been working on a revision
to its rules regarding CRTs for four years. Now that the special interest
groups have been successful in forcing people to recycle CRTs in California,
it seems likely that they will start in on the remaining states.

Gordon Davy
Baltimore, MD
[log in to unmask]
410-993-7399

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