I saw the various posts about the recent news articles and report about exporting e-waste
to Asia. I was inclined, inititally, not to get engaged in the debate, (at least in this
forum). I had drafted some responses and comments to the full report over the weekend and
after seeing David Suraski's posting I figured I would take the plunge.
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There have been recent news articles in the US and European press dealing with the export
of electronic waste to Asia. These articles were based on a report prepared by the Basil
Action Network (BAN) and the Silicon Valley Toxics Coalition (SVTC). However, a reading
of the report itself must make one wonder if the environment is really what BAN and SVTC
are concerned about protecting.
The report uses many of the same techniques used by the irresponsible sectors of the
environmental movement, using terms designed to evoke emotion rather than intelligent
thought. For example, referring to the situation as a "dirty little secret" - twice; a
"crisis" - 19 times; describing components of electronics as "poisons" - 8 times and
using terms such as "witches brew" - twice; and "quick and dirty". In addition, the
report consistently makes references to unstated sources when they could easily have
identified the source - "... informed recycling industry sources estimate ..."; "...
informed industry insiders ..., "... very knowledgeable and informed industry sources
..."; "... officials at the US Environmental Protection Agency ..."; "... solid waste
agencies and recyclers are anticipating ..."
Even when they actually quote a source, the data is suspect, if not outright false. One
of the referenced sources of data is another "report" about hi-tech industry done by one
of the contributors to this report - the Silicon Valley Toxics Coalition's "Poisons P.C.s
and Toxic TVs". This source, which is likewise highly flawed, was quoted as the
"authority" no less than seven times. Another "authoritative" source quoted is a piece of
draft legislation pending before the European Parliament. It, apparently, is their source
for technical (a have a hard time calling it scientific) information about lead. It is
not clear what the reference is for, since the endnote is attached to the word "Lead"
standing alone. Ditto on Mercury. Perhaps the source should have been the periodic chart
of the elements. One interesting and somewhat amusing point in their paragraph on lead
was the statement "... lead accumulates in the environment ..." I hate to burst their
little bubble, but since lead is an element, it is in the environment naturally and it
does NOT accumulate, the same amount was present when the earth was formed and the same
amount will be there when we are all consumed by an expanding sun a trillion years from
now. The principles of basic chemistry seem to elude the authors.
One statement "These heavy metals and other hazardous substances found in electronics can
contaminate groundwater." [by the way, note that it says "can" not "does" - cd] does
give a reference. The endnotes attributes the statement to a "Report for the United
States Environmental Protection Agency, Region IX, Computers, E-Waste, and Product
Stewardship: Is California Ready for the Challenge?" Note: the referenced report is not a
report done "by" the US EPA, it is a report done "for" the US EPA. Nor was the
referenced report done on behalf of the EPA. It was done "for the EPA" in the sense that
the authors wanted the EPA to read it (there is no evidence that anyone at the EPA
actually did read it). The report was actually done by a group called Global Futures
Foundation (see http://www.crra.com/ewaste/articles/computers.html ). The "Report for
the EPA" in fact states "... we want to make clear that the opinions and information
offered here are of our own making. This report does not represent the formal position
of the US EPA, ..." This is clearly an attempt by BAN to mislead the reader. It is also
another example of one activist group using an unscientific study by another activist
group as a resource for outlandish claims.
Some of the assertions in the BAN report border on the ludicrous "How much E-waste is
exported? The short answer [and probably the correct answer - cd] is that nobody really
knows. Yet anecdotal evidence on E-waste exported by the US to Asia is abundant. While it
is a secret well kept from the American public, it is well known in the E-scrap business
that very substantial percentages of what comes in their doors moves quickly off-shore."
Quite a transition from "nobody really knows" to "abundant" "anecdotal evidence" to "...
it is well known ..." Well, if it is well known then they should share the information
and the sources with the reader. And similarly "While there are no figures available,
the amount of computers being exported for reuse is increasingly significant." First, if
there are "no figures available" then how do they know the number is "increasingly
significant"? Second, what is wrong with "reuse"?
No sources are given for the alarmist and self serving statements such as "The growing
quantity of E-waste is beginning to reach disastrous proportions ..."; "... just now
beginning to grapple with the problem ..."; "... as E-waste begins to seriously inundate
solid waste disposal facilities and programs ..." Another interesting, and unsupported,
claim is that "According to the EPA in 1997 more than 3.2 million tons of E-waste ended
up in U.S. landfills." However, do the math, that is less than 23 pounds per person.
Doesn't sound quite so alarming, does it?
Another problem with the report is it keeps bouncing from one category of electronic
product to another, and when it suits the purposes of the authors they reference
statistics related to one category and lead the reader to believe that it is typical of
all electronic products. When talking about the growth of "E-waste" they in one instance
talk about refrigerators and air-conditioners then in the same breath quote a source (or
make a bold assertion without quoting any source) that discusses the rapid obsolescence
of personal computers and from that try to lead the reader to believe that all electronic
waste is growing as fast as computer waste. In addition, they consistently refer to
obsolescence of personal computers and equate that with waste. However, obsolescence of a
product and discarding of a product are quite different things. Many personal computers
and other electronics are "obsolete" but are still in use, or occupy the extra bedroom at
home. I can assure you that half of the electronic products in my home are obsolete, but
I still use them. When the new and better television is purchased the old one goes in the
bedroom or is given to the child who has gone off to college or is just starting a
household and who can not afford the most current product. Despite what the authors want
the readers to believe, obsolescent computers or electronics in general do not equate to
electronic waste. Moreover, rates of obsolescence AND disposal of personal computers is
not the same as the rates of obsolescence and disposal for washers and dryers, but that
is what the authors want us to believe.
The report, of course, blames the high tech industry, and treats consumers as poor dupes
at the mercy of producers. Note the comment "Where once consumers purchased a stereo
console or television set with the expectation that it would last for a decade or more,
the increasingly rapid evolution of technology combined with rapid product obsolescence
has effectively rendered everything disposable." The implication clearly is that
producers make disposable products that break down and require replacement after only a
short period of use. In fact, we all know that to be false. Obsolescence does not equate
to product failure. In fact, they admit as much - "Data from single day recycling
collection events has revealed that more than 50% of turned-in computers were in good
working order, but they were discarded nonetheless to make way for the latest
technology." Products are lasting longer than ever, it is just that some consumers chose
to buy newer versions of products when they are available (in many instances,
particularly for household appliances, because they consume less power and are cheaper to
operate). One has to ask BAN if they are proposing that innovation itself should be
stopped or that consumers should not be allowed to make their own purchasing decisions?
Of course, one of the silliest statement is "Americans are buying more computers than
people in any other nation." That may or may not be true, but I fail to see the
relevance of it, unless the purpose of the statement is to appeal to some deep seated
guilt among certain Americans.
One may think that this is a solid waste story, since so much time and effort is given to
the so-called "crisis" of solid waste. The problem is that in fact there is no solid
waste problem in the U.S. There is more than ample space and technology to handle the
volume of E-waste, if municipalities and states chose to do so. If municipalities choose
not to develop the new landfills to accommodate the waste, of all sorts, generated by its
residents than so be it, but that does not make waste generation the source of the
perceived problem. The report continues to make unsubstantiated claims "... all landfills
leak ..."; and "... landfills leak toxins ...". In fact, well engineered and well
maintained landfills do not leak.
The part of the report dealing with the only research actually conducted by BAN is also
revealing. From "... three intensive days..." of "... driving about Guiyu ..." they
attempt to draw conclusions about an entire industry in Asia. They admit their
investigation was not comprehensive, ("... we did not even come close to seeing all of
the operations ...") but that does not stop them from speculating that what they saw was
"... perhaps a view of the 'tip-of-an-iceberg.' " _Perhaps_ what they saw was not the
tip of an iceberg, but an ice cube, and they saw it all. China is a nation of 1.27
billion people spread out over an area of 9.6 million square miles. Its GDP, from figures
available as of April 2001 amounts to 1.23 trillion dollars, making it the second largest
economy in Asia and the third largest in the world. (See
http://www.eia.doe.gov/cabs/china2.html ) From a single, three day trip to one town in
China BAN presumes to draw a conclusion about the entire recycling industry - not only in
China, but the whole of Asia. In any other context this would be laughable.
During the "... three intensive days ..." BAN took "... one water sample, one sediment
sample, three soil samples..." I have no doubt that the pictures shown by BAN in the
report are not doctored and that they show pretty unsophisticated, and in all likelihood,
dirty, operations. But the analysis done by BAN is hardly justified by the skimpy
sampling, particularly when China suffers from major energy-related environmental
problems. According to a report by the World Health Organization (WHO), seven of the
world's ten most polluted cities are in China. (See
http://www.eia.doe.gov/cabs/china2.html ). How does one know if the pollution found by
BAN is purely the result of the recycling operations or is due to the generally polluted
nature of the country? Three days and five samples is hardly sufficient to condemn an
entire industry. BAN conveniently ignores the fact that sound environmental management
is a luxury of the wealthy, and the best way to bring sound environmental management
practices to China is to create wealth in that country.
The real purpose of the story is somewhat difficult to fathom, since it seems to be
critical of everything from recycling itself, to the general nature of high technology
products. They actually admit that they are not interested in recycling, even when it can
be done safely. "Thus, even if it were somehow possible for China, India or Pakistan to
possess state-of-the-art technologies, and possess the resources and infrastructure to
ensure that such technologies work optimally, the export of all of the world's E-waste to
Asia would still be an unjust, inappropriate export of pollution to a particular region
of the world simply because it is poorer." An interesting comment coming from people who
live within the confines of the comfortable and affluent Bay Area of Northern California.
The report goes on to say "Recycling of hazardous wastes, even under the best of
circumstances, has little environmental benefit, it simply moves the hazards into
secondary products that eventually have to be disposed of." I thought that was the whole
idea of recycling, to reuse products or their constituent elements in other products or
applications so that they do not end up in landfills. But like so much else of the
article their assertions are just not supported by the facts. In fact, recycling of
hazardous materials can benefit the environment (this is not to argue that all recycling,
even of non-hazardous materials, always benefits the environment, there are instances
where recycling, merely for the sake of recycling, can be wasteful and damaging). Mercury
is a good example: according to the US Geological Survey, virtually all mercury that is
commercially used in the United States comes from mercury recovered from industrial
products. (See http://minerals.usgs.gov/minerals/pubs/commodity/mercury/430302.pdf )
We are all familiar with the fact that steel from automobiles has been recycled for many
decades, aluminum and other metals and materials are recycled to a substantial extent in
the US.
Nor is the issue, preliminary appearances to the contrary notwithstanding, producer
responsibility. The report states, early on "The current U.S. Policy ... is not only an
affront to ... the principles of producer responsibility ..."; "... informed [but
unidentified - cd] recycling industry sources estimate that between 50 to 80 percent of
the E-waste collected for recycling in the Western US are ... bound for destinations like
China ..."; "Informed industry insiders [not identified - cd] have indicated that around
80% of what comes through their doors will be exported to Asia ..."; and " A pilot
program conducted by the US EPA that collected electronic scrap in San Jose, CA estimated
that it was 10 times cheaper to ship CRT monitors to China than it was to recycle them in
the US."
(As an aside, there are a number of problems with this last statement. First, the reader
is lead to believe that the footnoted source for this information is the US EPA, but it
is not, it is a "personal interview" with Craig Larch, a US based recycler. What did the
EPA study really show, why did the authors not quote from the study? Second, it is not
clear what the sentence actually means - I assume that it means that the cost to "ship"
CRT's to China is one tenth that of "recycling them" in the US. This does not say that
that is what is actually happening, it is merely a statement of the cost of doing one
thing versus the cost of doing something completely different. What is more relevant is
the question "what is the cost of shipping material to China AND recycling it there
versus the cost of recycling it in the US?" Is it possible that the cost of shipping to
_and_ recycling in China are equivalent to the cost of recycling in the US?)
In addition, they realize that to argue for producer takeback will get them in trouble,
because they have to admit that under any theory of producer takeback the material will
have to go back to Asia for recycling in any event because the bulk of electronics used
in the US is produced in Asia. Theirs is a rather interesting approach to "producer
responsibility". They state "Rather, the take-back must occur in the country and area of
consumption to minimize cross-border economic dumping and unnecessary transport." As
China's middle class continues to grow and enjoy the benefit of their wealth they too
will be producing E-waste, I assume BAN would not want them to ship that to the US, so it
will have to be handled in China, perhaps in the manner described in the report.
This takes us to what the report is really all about. It is not about recycling, it is
not about producer responsibility, it is simply an attack on free enterprise.
Statements include "Market forces, if left unregulated ..." - used twice; "... motivated
by brutal global economics." - used twice; and "The overwhelming majority of the world's
hazardous waste is generated by industrialized market economies." But the most revealing
statement is "A free trade in hazardous waste leaves the poorer peoples of the world
with an untenable choice between poverty and poison - a choice that nobody should have to
make." I do not agree that the choice is, in fact, one between poverty or poison, but I
do agree that, in the abstract, it would be nice, in a perfect world, if no one had to
make such choices. But this is not an abstract argument, and it is just too convenient
for the people from BAN and the Silicon Valley Toxics Coalition who live in comfortable
homes in northern California to make the decision for the people of China. Again, I do
not concede that it is a choice between poverty or poison, but even if it were, the
people affected should have the right to decide if they will live the rest of their lives
in poverty and die at an early age from some infectious disease or malnutrition, or
engage in an activity that will benefit them economically and raise them out of poverty
but which may, after fifty years of constant exposure, increase the likelihood that at
age 65 they will die with tumors in their bodies. Even this is a worse case scenario,
because as wealth and job opportunities increase and as the local economy grows, the
likelihood that a person will continue for a lifetime in the same "scrap recycling"
activity decreases.
The more one reads this report the more it becomes evident that recycling, the
environment and toxins are not the issue. The issue ultimately is free enterprise.
Again, quoting the report "The mere fact that cheap labor is exploited once by a
transnational electronic manufacturer in the production of a product is no reason to
exploit that very same low-wage labor population again at the end-of-life, particularly
if that exploitation involves hazardous substances." So here we have it, this is what it
is all about. BAN conveniently ignores the fact, that this so-called "exploitation" by
the hi-tech industries of the world has resulted in millions of citizens in the Asian
countries pulling themselves out of poverty and enjoying a much better standard of
living. In addition, if the so-called "hazardous substances" did not present a problem
when the products were being assembled, why then are they are the suddenly a problem, per
se, at end-of-life? If chemicals can be used safely in the manufacture of a product they
can be handled safely in the recycling of the product.
And it does not stop there. "By deregulating CRTs' the UWR [Universal Waste Rules - cd]
has had the unintentional result of saddling the cities with recycling costs while
lowering recycling standards, encouraging the use of prison labor." and "Supporting
prison labor sustains a policy that is morally corrupt and that invests in low tech,
labor intensive recycling ..." And of course they have to throw in the totally
gratuitous and completely irrelevant "California's prison system also competes with
university research funds and community economic development funding. In California, the
state prison system's $5.6 billion budget is larger than the $4.3 billion combined
budgets of the state's two premiere university systems ..." I suppose they would prefer
that prison inmates spend their time locked up in their cells or working out lifting
weights rather than engaging in something constructive, that might actually help them
find jobs when they are released.
What this is all about is "living wages" for people in the industrialized world and a
slap at free enterprise. We have already seen that BAN would not have this work done in
the third world (or by California convicts) even if it could be done cleanly and safely.
Chuck Dolci
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