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What Is -- and What Isn't -- Responsible Electronics Recycling

<p>Companies want to do the right thing when dealing with their discarded electronics, but a recycling certification developed by the industry and manufacturers is only muddying the waters. How do you know your recycler is working in line with your firm's principles?</p>

We are still sending toxic e-waste to developing countries, a poisonous trade that is legal and prolific. But now that 60 Minutes, Frontline, National Geographic, 20/20 and others have mainstreamed pictures of children playing amid piles of smoldering electronic scrap, the marketplace has firmly proclaimed what the electronics industry has never been willing to say -- enough!

After decades of looking the other way, the electronics manufacturers and scrap metal recyclers association (ISRI), facilitated by the EPA, are rushing to make a virtue of necessity by promoting a new electronics recycling certification. Called "R2," for "Responsible Recycling," it has been tailored to serve the electronics industry's special interests.

Meanwhile, a competing certification -- "e-Stewards" -- has been developed by a group of concerned electronics recyclers under the auspices of the Basel Action Network, an environmental organization with the singular mission of eliminating the toxic trade in e-waste with developing countries. Many of us involved in the development of the e-Stewards standard have been long-term evangelists for truly responsible recycling, which to us means: "No export of hazardous e-waste to developing countries, domestic recycling instead of disposal in incinerators or landfills, and no use of prison labor."
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Irresistible market and political pressures are forcing the electronics manufacturers and ISRI to come green, and they are desperate to make R2 a monopoly standard to ensure that they control the definition of what constitutes "responsible recycling." R2 is their blueprint for how that definition should serve their interests:

• R2 allows the export of untested electronics anywhere in the world so long as they are designated for resale and/or recycling in conformity with "R2 practices." In the absence of effective enforcement, R2 is virtually an open door to e-waste dumping.

• R2's list of controlled "focus materials" omits many toxic substances injurious to human health and the environment.

• R2 ignores the common practice of using prison labor for manual dismantling, whether in the United States or abroad -- an invitation for sweatshop recycling.

• R2 does not require an independently audited Environmental Management System consistent with ISO 14001, and lacks detailed guidance documentation for implementation. So the standard will be whatever the local R2 auditor says it is. The thoroughness gap is obvious by merely comparing the lengths of the two standards: R2 --15 pages; e-Stewards -- 49 pages, not including ISO proprietary content and a 67-page guidance document.

• R2 allows incineration for "energy recovery," when recycling is not "economically feasible," ensuring much of the plastic not burned in open fields abroad will go up smokestacks here at home. "Land disposal" is similarly permitted -- another common destination for hard-to-recycle plastics that make up over 60 percent of many electronics by weight.

• R2 does not require that all of a recycler's locations be certified, allowing recyclers to represent themselves as "R2 Certified" but behave however they wish in their unaudited facilities.

It's hard to argue with the moneyed interests behind R2, but their tactics suggest that its proponents do not consider themselves to be on the moral high ground: I have personally spoken with recyclers who report being threatened by the manufacturers they serve with a complete loss of business if they adopt the e-Stewards standard. Manufacturers are unwilling to close the door on hazardous exports to developing countries if responsible domestic recycling costs more.

The President of ISRI recently drafted a letter to the Chairman of the Congressional House Administration Committee in which he misrepresented the e-Stewards standard as having been "developed in a vacuum." In fact, the standard was developed with the input of leading recyclers and environmentalists in the industry, only after it was clear that the R2 standard would be deficient.

R2 lacks the support of the environmental community and some of the most prominent electronics recyclers in the United States. In fact, a number of recyclers now pursuing e-Stewards Certification were once participants in the R2 development process and walked away when it became clear that the manufacturers' special interests would prevail over truly responsible recycling practices.

Like R2, the e-Stewards standard has been accredited by ANSI-ASQ National Accreditation Board (ANAB) as a third-party auditable standard. I am pleased to report that Redemtech has completed its stage-2 e-Stewards certification audit, and that all nine of our facilities worldwide will be certified as e-Stewards ISO 14001 in the near future.

Certification is good in general for enterprise customers because it reduces the cost and increases the effectiveness of vendor governance and audit. It will ensure greater transparency from the electronics recycling industry. Companies concerned with issues of social and environmental responsibility should review the competing standards to judge which one unambiguously aligns with its policies. Every business is feeling the demand from its customers to be more sustainable, so it is in everyone's interests to hold the electronics industry to account for its environmental performance.

It is truly regrettable that only media exposure of the toxic e-waste trade finally motivated the electronics recycling industry to move toward greater responsibility. This is no time to tolerate special interest loopholes and grey areas.

Robert Houghton is president of Redemtech, a leader in providing Technology Change Management (TCM) services that help organizations manage IT assets to meet their environmental, social and financial goals.

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