Chuck,

WOW!

Brian

Charles Dolci wrote:
>
> 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.
>
> ----------------
> 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