The US Department of Commerce Technology Administration Office of
Technology Policy has recently issued a 152-page report titled
"Recycling Technology Products - An Overview of E-Waste Policy Issues."
The principal author and project leader is Laureen Daly. It is available
at http://www.technology.gov/reports/2006/Recycling/Beg-Apendix7.pdf.
When I learned of it I wanted to see how much space such a long and
government-supported report would devote to whether e-waste should be
recycled, and if it should, the reasons why. Sadly, I found very little.


Evidently the OTP regards it as so obvious that e-waste should be
recycled that no explanation is needed. The policy issue of "whether" is
not addressed at all. While I know that forum participants who have
posted an opinion on this topic have without exception expressed support
for the notion of government-mandated e-waste recycling (regardless of
how much it costs), I would hope that they would be fair-minded enough
to agree with me that, given what is at stake, a taxpayer-financed
report of this size should pay some attention to the "whether" policy
issue. I offer this admittedly long analysis to promote more rigorous
thinking about that issue.

Here are the only comments I could find in the entire document, all from
the introduction, that have any relevance to the question of "why". In
these excerpts I have added comments of my own in [brackets] and added
*emphasis*.

Excerpts:

As a result, lawmakers and policymakers have begun to turn their
attention to addressing this vexing and multidimensional issue.

This report does not seek to make recommendations or to determine
whether a particular electronics recycling system is better than another
[- because no consensus could be reached - nor does it assess whether
e-waste recycling is worth spending money on].

Several characteristics of e-waste - its *bulky nature*, the high cost
of *properly* managing it, its *potentially toxic* constituents -
distinguish electronics from ordinary trash.

Ewaste comprises one to three percent of municipal waste across the
United States. It is a small but fast-growing portion.

[... T]here is a not insignificant amount of lead in TV and PC monitors,
especially the older models - enough to cause most TV and PC cathode ray
tubes (CRTs) to test hazardous under Federal hazardous waste criteria
[even though the EPA has acknowledged that their TCLP test for this
application gives misleading results]. 

Product stewardship is a product-centered approach to environmental
protection. It calls on those in the product lifecycle - manufacturers,
retailers, users, and disposers - to share responsibility for reducing
the environmental impacts of products... [It] also embraces the concept
that products have materials in them that have a value; and that value
should be captured, preserved and returned for use in commerce [no
matter how much it costs to do that].

Many state and local governments want to see *manufacturer financed*
recycling programs for electronics because they feel they are unable to
add additional fees to their solid waste programs to provide
government-supported programs [because of concern about arousing
taxpayer opposition].

Over time, the ... participants realized that a national law might be
necessary to *force* otherwise reluctant *players* to do their part to
make a national system work.

The Office of Technology Policy (OTP) of the Technology Administration
held a Roundtable on electronics recycling on September 21, 2004, to
examine some of the major issues outstanding between stakeholders: most
particularly the financing issues.

Language Analysis Primer: 

I have commented in previous postings about how environmental activists
frame the e-waste recycling discussion by deftly directing attention
away from "whether" and "why" to "how." While activists seem to have a
low regard for facts and rigorous thinking that don't fit their agenda,
they are highly skilled in the use of language. In getting people to buy
into their agenda they strongly assert that there is a problem but make
only the vaguest of allusions to support those assertions. Presumably
because they recognize that they don't have a case, they know that the
more they say about "why" and the longer they take to get to "how," the
greater their risk of being challenged. This report gets to "how" very
quickly. 

I do not know Ms. Daly or what she believes, but the activist influence
in this report can be seen clearly. The excerpts above are brief, but
they are rich in examples of how activists use language to promote their
agenda. Here is a twelve-point primer in how to decode that language.
Note: 

*    that e-waste recycling is said to be a "vexing and multidimensional
issue." This is because agreement is lacking on how to make people pay
for it. Actually, it is an issue only because environmental activists
have claimed that it is an issue and have succeeded in getting enough
other "stakeholders" to believe - or fear - them and participate in
discussions.

*    that saying there are "several" distinctions and listing just three
suggests that these three are just representative and that there are
other significant distinctions that might have been enumerated. 

*    the claim that e-waste is "bulky." I take that to mean either
"large" or "of low density". If it's the former that is meant, e-waste
comes in a wide range of sizes, just as does other waste. If the latter,
e-waste is of much higher density (mass per unit volume) than most
constituents of municipal solid waste - think garden debris or coffee
grounds or just about anything that you put into a trash can every day.
You don't need special training to know what e-waste and municipal solid
waste are like. And in either case, why is "bulky" even relevant? 

That so many smart and important people who must have read and approved
this federally-funded report before it was published could have believed
that e-waste is bulky, or that it matters, says more to me about their
beliefs than their thinking. Even this small example shows that you do
need to be able to think for yourself to avoid being deceived by
misleading language from people with an agenda.

*    the reference to "the high cost of properly managing" e-waste
disposal. The "high cost" refers to the fact that properly managed
e-waste recycling must be subsidized. The use of the term "properly"
cleverly implies, without supporting evidence, that everyone agrees that
unmanaged disposal (i.e., incineration or landfilling) is improper.
(Unregulated recycling is of course a different matter entirely, as has
been discussed in many previous postings.)

*    the reference to "potentially toxic." There is no reference to any
cases of poisoning, even though e-waste disposal has been completely
unregulated for as long as there has been e-waste - almost a century.
This boogeyman language says in effect, "We have no evidence that there
have ever been any bad consequences, but we can't afford to take the
chance that some day there might be some." 

Ask yourself how this differs from superstition. Missing is any sense of
priority that should be assigned to this problem or why out of all the
problems in the world they picked this one to devote their attention to.
Ask yourself how significant this issue is to the activists in
maintaining a positive cash flow for their organizations.

*    the grudging and veiled mention that e-waste is a minor constituent
of municipal solid waste, and the attempt to put a positive spin on the
facts. It is to OTP's credit that they acknowledge the "one percent"
fact at all - most discussions fail to mention it, for understandable
reasons. Another part of the Commerce Department has issued data showing
the actual value to be about one percent, not three, and while the
percentage is increasing, it isn't increasing very fast. For the
foreseeable future - despite inflammatory claims, photos, and references
to "millions of pounds" - it should be clear that the volume of e-waste
is a non-issue.

*    the use of the terms "responsibility" and "environmental impacts."
Isn't it remarkable in a culture in which so many people subscribe to
moral relativism ("it may be true for you but it isn't true for me so
don't try to influence my beliefs") that activists can be so influential
with their dogmatism? By appealing to "responsibility" as if there were
a consensus on what that means they seem able to avoid a reaction to
their attempt to impose their beliefs on the rest of us. 

As with the word "properly" above, the activists expect us to take as a
given that there are environmental impacts associated with uncontrolled
disposal of electronic products, and that paying for e-waste recycling
is the responsible thing to do. 

While it is certainly true that disposal of some substances can harm the
environment (e.g., spent sulfuric acid) and hence must be regulated to
prevent that harm, you will look in vain in this report for a list of
environmental impacts from unregulated e-waste disposal. Do you think
that this was an inadvertent omission? Yet without a documented impact,
the entire issue not only stops being vexing - it simply vanishes. (See
below for my discussion on sustainability.)

If this sounds simplistic, it is because the activists have been so
convincing that their "issue" is more than make-believe. People often
reason "surely with this much smoke there must be a fire." Instead,
think smoke and mirrors.

*    the attempt, by officials who are being paid to represent
taxpayer-consumers, to hide the cost of subsidized e-waste recycling
from the people who are paying them. The term "manufacturer financed"
suggests the curious notion that the manufacturer is somehow going to
absorb the cost of the recycling and not pass it along to the consumer.
This is of course not true (nor will distributors or retailers absorb
the cost either). However, doing it this way may well hide the cost from
the consumer. This is what the tax-supported members want, to reduce the
risk of a grass-roots revolt against what they would like to have
enacted. 

Opponents of government-coerced recycling do not get invited to meetings
of "stakeholders," even though they along with all of the other ordinary
citizens will be expected to pay for whatever scheme gets hatched. Maybe
the organizers couldn't find any opponents, or maybe they didn't see the
need to since environmental activists purport to be altruistic champions
for ordinary citizens. Maybe some activists started out that way, but
they are not now. As with everyone else in the discussions, activists
who are responsible for sustaining and funding their organizations are
looking to promote their own interests and influence.

*    the explicit use of the word "force." This mention of the "F-word,"
rare for people in polite company, is surprisingly candid. Maybe the
proponents are getting frustrated by lack of progress. They can't agree
among themselves and of course as policy recommenders they aren't in a
position to exert force. Presumably they hope to influence legislators
to exert the force for them.

*    the use of the phrase "otherwise reluctant players." This phrase
implies that this policy issue is some sort of game and that dissenters
are being uncooperative. It also disguises the fact that it is
taxpayer-consumers or their paid representatives who are being referred
to. Do you detect a note of elitism?

*    the veiled acknowledgement that the major issue (not one among
many) is financing. Here's the biggest "how" - how to pay for subsidized
e-waste recycling. That is what has prevented agreement for many years
now among the "stakeholders." Wouldn't you think that with all that
reluctance to pay, someone in the discussions would have questioned the
value of what was being paid for? But apparently not. Maybe no one was
willing to risk the censure of everyone else. And since most of the
money would be coming from other people why bother?

*    finally, the reference to value in materials. Interestingly, this
report mentions it almost in passing (one sentence). Not surprisingly,
it omits any mention of the cost of capturing, preserving, and returning
those materials for use. This is the "sustainability" policy issue.
Although the report scarcely mentions it, I now discuss it in some
detail. The most complicated to understand, it is the reason that forum
proponents give most often in support of forced e-waste recycling -
probably because they are too well informed to fall for the other
activist claims.

Sustainability:

Everyone knows that there are plenty of everyday end-of-life items that
are not worth recycling. By ordinary reasoning (i.e., common sense),
when one perceives that the cost of extracting value from an item
exceeds its value afterwards (e.g., pantyhose with a hole in it), it is
trash, not a candidate for recycling. 

There are plenty of examples of valuable materials that are being
disposed of daily in municipal solid waste. One, notably, actually has a
higher weighted-average value: edible food. By the activists' logic,
that food should also be rescued, particularly because there are hungry
people in the world who would benefit greatly if it were provided to
them. 

By what rationale should we preserve resources such as metal ore for
unborn generations and neglect malnutrition among people alive today -
malnutrition that could be allayed by salvaging and distributing
discarded food? It won't do to say that salvaging food from waste isn't
practical unless one is prepared to state the basis used to decide what
is practical. After all, the issue is whether salvaging metals from
e-waste is practical.

What kind of altruism is it to be more concerned about one's own distant
descendants than other people who are alive and suffering right now? One
must wonder how sincere such advocates really are. Some seem to have
already decided on the basis of intuition that government-mandated
e-waste recycling is a good and noble thing to do. Then because they
feel they need to give some rationale for their intuitive belief they
rationalize, using the sustainability argument as the best one
available. Maybe they haven't really thought about the issue very
deeply, but feel virtuous saying that it is good and noble even if they
can't support that opinion rigorously. 

The value being referred to for e-waste recycling is primarily in
metals, which come from non-renewable resources, so lest someone object
that my reference to food is irrelevant, consider that pantyhose comes
from petrochemicals - which also come from a non-renewable resource.
Therefore if one wants to make a case for extracting value from e-waste
and not from pantyhose waste, he needs to declare his basis for the
distinction. What kind of sense is there in saying that everything in
the waste stream that has any value should be recycled - even if it does
come from a non-renewable resource? Remember that metals cannot be
rescued from e-waste without petroleum being consumed. 

Further, even the most efficient recycling doesn't rescue all the metal.
One who is willing to tolerate the disposal of the remaining un-rescued
metal must accept some limits. He needs to state how he decides how much
metal disposal after recycling he is willing to accept - the maximum
concentration value of, say, tin, remaining in waste after recycling. 

After all, why not extract more tin by other techniques, such as ion
chromatography (very expensive)?  Remember, we're talking concepts here,
not cost effectiveness, since proponents don't like to discuss that.
When one says (or implies) that e-waste recycling to extract metals by
is a good and noble thing to do, is extracting more metal better and
nobler? 

Recognize that there will be waste after e-waste recycling, and that if
the e-waste going into the recovery process contains tin, the recovery
waste will also contain tin. Those who understand the second law of
thermodynamics know that no process is entirely efficient and that it
will never be possible to eliminate waste entirely. Those who don't may
become convinced otherwise if exposed to clever enough proclamation.

People who express their acceptance of coerced subsidy of e-waste
recycling never qualify it with how much cost is warranted - they seem
to be blithely willing for government to make everyone write a blank
check for it, ignoring the loss of value to the economy of other uses of
that money. They seem to miss the fact that such thinking is not
thrifty, but wasteful, because of the need for the infusion of money to
subsidize it. 

For these people, and for the OTP, it appears that the only "vexing"
issue is how to force people pay for it, not whether the benefit
outweighs the cost. Yet with more rigorous thinking that includes all
the relevant facts, the answer to the sustainability policy issue is a
lot less obvious than so many forum subscriber-proponents seem to have
believed.

Proponents sometimes express the notion that e-waste recycling will some
day become self-supporting if we can just get the system implemented,
but I don't recall seeing any argument showing that to be any more than
wishful thinking. It bears repeating that were that to happen, the
evidence would be that force is no longer necessary to keep it going -
just as no force is needed to promote automobile recycling.

Challenge - Explain Your Faith:

Since statements of support for government-mandated e-waste recycling
continue to be expressed from time to time on this forum, I conclude
with a challenge to those who post such statements. I have posted this
challenge before, but here I state it even more emphatically. If you
have been upset by what I've posted before, you won't want to read any
farther. 

If you believe that the benefit to our world and our progeny is worth
forcing people to pay to recycle e-waste, first explain your
qualifications to offer an opinion on the matter. (Why should people
believe that you know enough about this subject for them to pay
attention to what you have to say? Being smart or articulate or
well-paid or a respected expert in some other field, appealing to
intuition or feelings, and uttering mantras of received wisdom don't
count!) Then present the cost-benefit analysis that you used to reach
your conclusion. 

Be rigorous - no hand waving! Remember that those who advocate a change
bear the burden of proof. (As you weigh all the consequences of making
the change, don't overlook the activists' precautionary principle. They
trot that out any time they are trying to discourage a change they don't
like, but if it is to be used at all it needs to be used uniformly for
any change.) Don't just say that e-waste recycling will reduce mining of
metal ore. That's hand waving. State the extent, the basis of your
estimate, and show it to be significant.

If you cannot present such an analysis, *please do not advocate that
government act to reduce people's freedom*. Unjustified government
coercion is not good or noble - it is government-sanctioned crime.

If you believe that government-mandated e-waste recycling is good and
noble but have not seen and cannot present such an analysis, don't just
keep your opinion to yourself or just share it with other believers.
Quite frankly, I want to undermine your faith. Why not reflect on how
you came to that faith?

Forum participants are mostly technical types, not touchy-feely. They
get paid to think rigorously and get right answers. So don't even allow
yourself to think "I like it because it makes me feel virtuous." Don't
ignore the F-word. How sure are you that this situation warrants the use
of force to make the good and noble happen? Might you have been misled
by activist slogans or by your own intuition? Might your appeal to
sustainability have been rationalizing?

Don't take today's universal support for government-mandated e-waste
recycling as evidence that it is a good idea. If you review the early
Leadfree forum archives, you will find lots of displeasure being
expressed toward those who asserted that prohibiting lead in electronics
is a bad idea. Long-time subscribers will remember that there was enough
criticism to prompt the formation of a separate strictly technical
no-lead forum to placate those who didn't want to have to read - or even
just delete - such assertions. 

Those who objected to the anti-prohibitionists didn't offer much in
support of prohibiting lead, but it must have bothered some of them to
be reminded that they were working on a project with no redeeming value
beyond keeping their employer in business without being prosecuted.
(After all, that's what attorneys are paid to do. Engineers like to see
themselves as responding to a higher calling even if they are not as
well compensated.) At the time, the anti-prohibitionists were in the
minority. 

Today, the censuring voices have become silent, while the voices of
those who think prohibition is a bad idea are becoming louder. So far,
those voices are saying in effect that the people who brought us the
RoHS and WEEE directives got one horribly wrong but got the other one
right. 

Is it too much for me to hope that some forum participants who take that
position today will not just ignore my challenge but evaluate their
beliefs? Is it too much for me to hope that some forum participants will
some day openly express doubt about the wisdom of forced e-waste
recycling, and concur that WEEE is no better than RoHS?

 

Gordon Davy 


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