Response (draft)

Please note: the version below is the final edition and was submitted as our official response.

Re: RCBC Computer Reuse Organization Standard

Free Geek's membership met recently to discuss the proposed standard. We are very encouraged by the spirit of the document, particularly in its attempts to link acceptable re-use guidelines to transparency. We strongly agree that there is a critical need to certify re-use organizations and resellers in BC, and that strict standards to which these organizations can be held will go a long way toward eliminating unethical or illegal practices. However, our membership has a number of serious concerns, which will be described in detail later in this document along with proposed resolutions, the most serious being as follows:

1. We are uncomfortable with formal requirements to endorse BC's EPR program, and to the mandatory direction of all unusable electronics to recyclers chosen without our consent. As a community-based organization promoting transparency and accountability, we cannot commit to supporting a program which has not yet been explicitly defined and which we have not audited. An organisation like ours must always reserve the right to seek better alternatives where possible, without bias. Additionally, we consider articulated standards more constructive than mandatory recyclers.

2. We consider the residual lifespan criteria to be wastefully restrictive. It would needlessly prohibit innovative reuse and repurpose models, and greatly reduce the amount of reusable product, inherent educational benefits and research opportunities.

The remainder of this document comprises a detailed listing of all of our concerns, proposed resolutions, and commentary from the Basel Action Network.

A. Pledge of Stewardship

We will address each item individually.

1. We strongly agree with the majority of this item. However, clarification of the term "incineration" would be helpful, and how it relates to smelting. There has been speculation that e-waste collected at official depots will be wholly smelted; this would hinder re-use organizations from participating meaningfully in the program.

2. An organisation like ours must always reserve the right to seek better alternatives where possible, without undue bias. At this time we are unable to evaluate the program's environmental practices, as they have yet to be fully articulated. Therefore we cannot commit to directing unusable electronics to the provincially mandated e-waste stewardship program. Instead of a mandated recycler, we prefer articulated standards like those provided by the Basel Action Network (e.g. no prison labour, not shipping to non-OECD countries; see the BAN pledge at http://ww.ban.org/pledge/electronics_recycler_pledge.pdf)

3. We agree.

4. We agree, with one minor edit: "reload the operating system" should become "reload an operating system", to allow for the operating system loaded being different from the one previously resident on the disk prior to wiping.

5. We agree.

6. We consider transparency essential to regulation, and are pleased to see industry-led pressure on this front. However we are reluctant to submit all re-use data to ESBC as it is an industry group, rather than a government or public body. We consider it more appropriate to require that every re-use organisation make these details available to the general public, in an easily accessed location such as a website or wiki. For some time, other Free Geeks have taken some such measures voluntarily as a matter of course. (See an example at http://wiki.freegeek.org/index.php/PDX_Recycling_Vendors)

7. We agree to the spirit of the item. However, we are concerned that the cost of such insurance may be prohibitive to smaller organizations and must withhold final comment until we have researched the matter.

8. We feel this point is considerably vague; the term "product" requires elaboration. How does it relate to the components of a computer, which may be disassembled and reassembled? CRT monitors could be tracked, but almost every component inside a computer could be swapped out; some of these parts may be reusable and some not. Also, we would like assurance that organisations are not required to collect personal information about the persons donating the product, to maintain individuals' privacy.

9. We are uncomfortable with formal requirements to endorse BC's EPR program. As a community-based organization promoting transparency and accountability, we cannot commit to supporting a program which has not yet been explicitly defined and which we have not audited. We desire further details regarding the phrase "co-operating with program stakeholders." All organisations should be encouraged to incessant pursuit of best environmental practices, and to bring public attention to any practice that falls short. In this spirit it is our pleasure and duty to work with others to improve the program.

10. We agree.

B. Residual Lifespan Criteria

With respect to systems for export to developing countries: We agree that there is an urgent need to regulate the type of systems sent overseas for "re-use", as most hardware currently shipped under this label is in fact scrap. An age limit is probably a better indication of the remaining lifespan of the system; more detailed specifications, such as processor speed or hard disk size, are unnecessary, since they are directly correlated with the system's age, and will in fact change over time, necessating updating of the standard.

However, we must note that Free Geek does not consider sending used items to less developed countries to be appropriate unless there is clear provision either for proper recycling in those countries, or for shipping the items back to developed countries where they may be properly recycled.

With respect to systems re-used domestically or in developed countries: We find the proposed minimum requirements to be overly simplistic and unsuited to the practical issues inherent in computer technology reuse, for the following reasons:

1. Computers are treated as a whole, with no provision for dismantling machines and reusing or replacing parts. Some parts can be repurposed for other purposes, like using old printer components for robotics research, or using systems or parts for cultural/artistic endeavors or as film props. Occasionally, there are direct applications for legacy hardware in the corporate and public sector, such as old floppy disk readers, or keyboards for expensive industrial manufacturing infrastructure. (See http://freegeekvancouver.org/en/GVRD_legacy_reuse) Older industrial machinery in particular can expand its longevity by replacing worn-out hard-to-find components.

2. There is no provision for free or open-source software as an alternative to propriety operating systems. Open source software can prolong the lifetime of older hardware and enables lower-cost refurbished systems, since there is no need to purchase new software licenses.

3. Our experiences have shown that the proposed minimum standard would wastefully divert a large amount of working, reusable hardware to recycling. In particular, thin client networks can be created using one powerful server and many less-powerful client computers. An example is the Linux Terminal Server Project (LTSP), recently adopted by the Kamloops District 73 School (see article: http://www.sd73.bc.ca/district-operations.php/page/linux-in-education/). Free Geek's own LTSP lab is composed of Pentium-III 500mhz computers.

Our membership is generally is agreement that, with the possible exception of overseas shipping, a residual lifespan criteria is wastefully restrictive. It would needlessly prohibit innovative reuse and repurpose models, and greatly reduce the amount of reusable product, inherent educational benefits and research opportunities.

C. Implementation Plan

We would like a definition of "person-to-person exchanges".

D. Conclusion

We support in principle the regulation of computer reuse organizations in BC. We look forward to further involvement in the development of this program.

Appendix. Commentary from Basel Action Network

Free Geek's opinions on e-waste and recycling are strongly influenced by those of the Basel Action Network (BAN). The following is a BAN statement articulating their position.

Basel Action Network maintains that:

1. Advanced recycling fees are not a good financing mechanism in that they do not involve the manufacturers in the end-of-life management of their products, and thereby do nothing to drive redesign for the environment and human health. If manufacturers have to pay for end-of-life costs (e.g. via incorporating these costs into the price of a new product), then they have a direct economic incentive to redesign their products to be less toxic, more upgradeable, more easily recycled, and perhaps longer lived. Ultimately, toxic waste issues must be addressed upstream in the manufacturing phase of a product’s lifecycle.

2. Reuse of electronics is environmentally preferable to destruction, but only if tested working and labeled equipment with a long life is allowed into the reuse market, and particularly the developing countries. Both the EU and Australia have developed detailed criteria for determining when a used electronic is a product acceptable for exporting for reuse, or is a waste, based on interpretation of the international treaty (Basel Convention) that governs the trade in toxic wastes. (www.basel.int) Our criteria for tested working equipment would allow for older equipment that runs on open source software to be allowed into the reuse market, if it is tested and fully functional, and has a reasonable life expectancy.

3. Refurbishment/repair of equipment generated in developed countries such as Canada or the US must occur in the developed world prior to export to developing countries, if those repairs will result in the replacement or removal of a hazardous part (such as circuit boards, CRTs, fluorescent lamps, batteries, etc.) In order to determine what types of repairs are needed, testing must be accomplished.

4. Smelters play an important role in reclaiming metals from materials. Because smelting always creates toxins, it is important to only use smelters that use the best technology to minimize the creation of dioxins and furans, and to capture toxic air emissions. Circuit boards and other metal-bearing e-scrap generated in developed countries should only be smelted in developed countries. We support the use of smelters in countries such as Canada, US, Belgium and Sweden, rather than using smelters in the developing countries. We do not support sending this entire e-waste stream directly to smelters, where much of the materials are not reclaimed, but rather are burned (which is a form of disposal, including waste-to-energy processes.) End-of-life electronics should be manually or mechanically separated and subsequent materials sent for material separation and reuse (e.g. plastics back into plastics usage, etc.) rather than burned or used as BTUs in a thermal process, even in waste-to-energy facilities. Thermal processing of plastics impregnated with brominated flame retardants can create brominated dioxins and furans at certain temperatures.