Exporting Harm
The High-Tech Trashing of Asia
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February 25, 2002
Prepared by
The Basel Action Network (BAN)
Silicon Valley Toxics Coalition (SVTC)
With Contributions by
Toxics Link India
SCOPE (Pakistan)
Greenpeace China
Authors: Jim Puckett, BAN
Leslie Byster, SVTC
Sarah Westervelt, BAN
Richard Gutierrez, BAN
Sheila Davis, MFF
Asma Hussain, SCOPE
Madhumitta Dutta, Toxics Link India
Edited by: Jim Puckett, BAN
Ted Smith, SVTC
China Investigative Team:
Clement Lam, Investigator, Interpreter
Jim Puckett, Investigator
Driver (desires anonymity)
Logistical Support:
Miranda Yip, Greenpeace China
Howard Liu, Greenpeace China
Film Available: VHS format video with the same title: "Exporting Harm". For $50 donation. Please send check to the Basel Action Network (BAN).
Table of Contents
Executive Summary...................................Page 1
E-Waste......................................................Page 5
What is It?..............................................Page 5
How Much E-Waste is There?..................Page 5
Where Does E-Waste Come From?..........Page 6
Where Does E-Waste Go?.......................Page 6
Hazards in E-Waste..................................Page 9
Export: The Great Escape Valve............Page 11 Recyclers as Waste Traders..................Page 11
Debunking Export Rationalizers.......... Page 13
How Much is Exported?.........................Page 14
China: The Story of Guiyu........................Page 15
A Community Transformed...................Page 15
Waste Origins........................................Page 16
The Recycled Materials.........................Page 17
Hazardous Recycling Operations..........Page 17
India and Pakistan...................................Page 23
Karachi, Pakistan.................................Page 23
New Delhi, India....................................Page 25
Asian E-Waste Impacts (Table)..............Page 26
Legal Implications of E-Waste Export....Page 27
Is E-Waste a Hazardous Waste?...........Page 27
U.S. Policy and Law...............................Page 28
Chinese Law..........................................Page 30
Basel Convention Implications.............Page 32
The Dilemma of Local Governments.......Page 35
Seattle, King County, Washington..........Page 35
California State.....................................Page 37
The Solution Lies Upstream.....................Page 40
Recommendations for Action................Page 40
The European Model.............................Page 42
What We Can Do....................................Page 43
Annexes
I. Materials Found in a Computer..........Page 44 II. Guiyu Sediment/Soil Results...............Page 45
III. Guiyu Water Samples..........................Page 46
IV. List of Labels and Brand Names.........Page 47
V. Example of Broker Solicitation...........Page 48
Basel Action Network
c/o Asia Pacific Environmental Exchange
1305 4th Ave., Suite 606
Seattle, WA. 98101
Phone: +1.206.652.5555, Fax: +1.206.652.5750
E-mail: info@ban.org, Website: www.ban.org
Silicon Valley Toxics Coalition
760 N. First St.
San Jose, CA. 95112
Phone: +1.408.287.6707, Fax: +1.408.287.6771
E-mail: svtc@svtc.org, Website: www.svtc.org
Greenpeace China
1/F Tung Lee Commercial Building
95 Jervois St., Sheung Wan
Hong Kong
Phone: +852.2854.8300, Fax: +852.2745.2426
E-mail: howard.liu@dialb.greenpeace.org
Website: www.greenpeace-china.org.hk
Toxics Link India
H-2 Jungpura Extension, Ground Floor
New Delhi, India 110014
Phones: +91.11.432.8006/0711
Fax: +91.11.432.1747
email: tldelhi@vsnl.com
Website: www.toxicslink.org
Society for Conservation and Protection of the Environment
(SCOPE), D-141 (annexi), Block2, PECHS
Karachi - 75400, Pakistan
Phones: +92.21.455.9448, 452.2562
Fax: +92.21.455.7009
E-mail: scope@khi.compol.com
Exporting Harm
Electronic waste or E-waste is the most rapidly growing waste problem in the world. It is a crisis not only of quantity but also a crisis born from toxic ingredients _ such as the lead, beryllium, mercury, cadmium, and brominated- flame retardants that pose both an occupational and environmental health threat. But to date, industry, government and consumers have only taken small steps to deal with this looming problem.
This report reveals one of the primary reasons why action to date in the United States has been woefully inadequate. Rather than having to face the problem squarely, the United States and other rich economies that use most of the world's electronic products and generate most of the E-Waste, have made use of a convenient, and until now, hidden escape valve _ exporting the E-waste crisis to the developing countries of Asia.
Rather than having to face the E-waste problem squarely, the United States has made use of a convenient, and until now, hidden escape valve — exporting the crisis to developing countries of Asia.
Yet trade in E-waste is an export of real harm to the poor communities of Asia. The open burning, acid baths and toxic dumping pour pollution into the land, air and water and exposes the men, women and children of Asia's poorer peoples to poison. The health and economic costs of this trade are vast and, due to export, are not born by the western consumers nor the waste brokers who benefit from the trade.
The export of E-waste remains a dirty little secret of the high-tech revolution. Scrutiny has been studiously avoided by the electronics industry, by government officials, and by some involved in E-waste recycling. This often willful denial has been
aided by the cynical labeling of this trade with the ever-green word "recycling".
The current U.S. system begins its path of failure before the electronics ever enter the marketplace. First, manufacturers refuse to eliminate hazardous materials or design for disassembly. Second, government policies fail to hold manufacturers responsible for end-of-life management of their products. Thus, finally, consumers, are the unwitting recipients of a toxic product abandoned by those with the greatest ability to prevent problems. Left with few choices, consumers readily will turn to recycling. But it appears that too often, this apparent solution simply results in more problems, particularly when the wastes are toxic.
The open burning, acid baths and toxic dumping pour pollution into the land, air, and water and exposes the men, women, and children of Asia's poorer peoples to poison.
While there are many E-waste recyclers who espouse and practice sincere environmental ethics and are trying to make the most of poor upstream design, there are many others whose "recycling" claims offer false solutions— recycling via export directly, or indirectly through brokers. Indeed, informed recycling industry sources estimate that between 50 to 80 percent of the E-waste collected for recycling in the western U.S. are not recycled domestically, but is very quickly placed on container ships bound for destinations like China. Even the best-intentioned recyclers have been forced, due to market realities, to participate in this failed system. They see that the real solution is producer responsibility.
Few of us realize that the obsolete computer we pay someone to
take, in hopes it would be recycled, might end up in China or some
other far-off Asian destination. Although it has been a
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secret well-kept from most consumers, the export "solution" has been a common practice for many years. But until now, nobody, not even many recyclers, seemed to know the Asian fate of these "Made-in-USA" wastes, or what "recycling" in Asia really looks like. And it was clear that many did not want to know. Hopefully, the evidence in this report will separate recyclers who believe in an environmentally superior solution from waste brokers looking for a quick buck.
Informed recycling industry sources estimate that between 50 to 80 percent of the wastes collected for recycling are not recycled domestically at all, but very quickly placed on container ships bound for destinations like China.
It became increasingly evident that a field investigation was long overdue. The Basel Action Network (BAN), a global watch-dog network focused on toxic trade, with support from member organizations of another activist network, "Waste Not Asia", and the Silicon Valley Toxics Coalition, a coalition advocating for a clean and safe high-tech industry, conducted an investigation that provides the basis for this report and an accompanying film. The findings documented in China, India and Pakistan should toll a loud alarm and signal a clarion call for sweeping changes in U.S. national policies and practices.
Until now, nobody, not even many of the reputable recyclers, seemed to know the fate of these "Made-In-USA" wastes in Asia and what "recycling" there really looks like. And it was clear that many did not want to know.
As detailed and illustrated in this report, the field
investigation revealed extremely hazardous and dangerous E-waste
"recycling" operations that pollute the air, water, and soil of
Asian countries. These operations are very likely to be seriously
harming human health. Vast amounts of E-waste material, both
hazardous and simply trash, is burned or dumped in the rice fields,
irrigation canals and along waterways.
A free trade in hazardous wastes leaves the poorer peoples of the world with an untenable choice between poverty and poison _ a choice that nobody should have to make.
E-waste exports to Asia are motivated entirely by brute global economics. Market forces, if left unregulated, dictate that toxic waste will always run "downhill" on an economic path of least resistance. If left unchecked, the toxic effluent of the affluent will flood towards the world's poorest countries where labor is cheap, and occupational and environmental protections are inad-equate. A free trade in haz-ardous wastes leaves the poorer peoples of the world with an untenable choice between poverty and poison _ a choice that nobody should have to make.
It was in an effort to counter the unsustainable and unjust effects of free trade in toxic wastes, that an international treaty known as the Basel Convention was created in 1989. And it was also for this reason that the Basel Convention in 1994 agreed to adopt a total ban on the export of all hazardous wastes from rich to poor countries for any reason, including for recycling.
The Basel Convention calls on all countries to reduce their exports of hazardous wastes to a minimum and, to the extent possible, deal with their waste problems within national borders. Indeed, this is an obligation of the Basel Convention regardless of the level of waste management technology in the importing country.
One would think that a country like the United States would be a
country most able to fulfill and implement this call for
national
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self-sufficiency in waste management. But, to date, the United States is the only developed country in the world that has not ratified the Basel Convention. In fact, U.S. officials have actively worked to defeat, and then to weaken, the Basel waste export ban.
The U.S. government policies appear to be designed to promote sweeping the E-waste problem out the Asian back door. Not only has the U.S. refused to ratify the Basel Convention and Ban, but in fact, the United States government has intentionally exempted E-wastes, within the Resource Conservation and Recovery Act, from the minimal laws that do exist (requiring prior notification of hazardous waste shipments) to protect importing countries. When questioned, officials at the United States Environmental Protection Agency (EPA) admit that export is very much a part of the U.S. E-waste disposal strategy and the only issue of concern for the U.S. might be how to ensure minimal environmental standards abroad.
The U.S. government policies appear to actually be designed to promote sweeping the E-waste problem out the Asian back door.
But this type of thinking belies the reality of conditions in developing countries and conveniently ignores the failures of the electronics industry to design their products so that they can be safely recycled anywhere in the world. As long as electronic products continue to contain a witch's brew of toxic chemicals and are designed without recycling in mind, they pose a threat at their end-of-life. As electronic products are currently constituted, E-waste recycling operations, in any country will generate polluting residues and emissions.
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.
It is sadly ironic that the United States was the first country in the world to recognize and uphold the principle of environmental justice. This principle asserts that no people, based on their race or economic status should be forced to bear a disproportionate burden of environmental risks. While the United States has begun to institute some programs at home to prevent environmental injustice, U.S. policy has actually promoted such injustice on the global stage.
While the United States has instituted programs at home to prevent environmental injustice, U.S. policy has actually promoted such injustice on the global stage.
The current U.S. policy of encouraging the quick and dirty route of export, hidden under the green cloak of the word "recycling", is not only an affront to environmental justice but also to the principles of producer responsibility, clean production and pollution prevention. Such export stifles the innovation needed to actually solve the problem at its source _ upstream at the point of design and manufacture. As long as manufacturers can evade the ultimate costs of their hazardous products via export to Asia, they can delay aggressively deploying their ingenuity to make sure their products are less toxic and burdensome to the planet. This is particularly true for electronic products because of their significant toxicity and their rapid obsolescence.
Export stifles the innovation needed to actually solve the problem at its source _ upstream at the point of design and manufacture.
In this regard, with little incentive the electronics industry
in the United States has, for the most part, moved at a snail's
pace in preventing the problem at the source through green,
toxic-free design. Instead, thanks to the convenient pipeline of
export, industry, aided by government, has taken a
head-in-the-sand, business-as-usual, for-as-long-as-possible
approach.
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As a result, local governments and consumers are now faced with an untenable situation. We are left with very few moral, sustainable choices as to what to do with our E-waste. The mantra accepted on faith diversion from landfill to recycling, now faces a serious reality check as that push may, without responsible action, likely result in ever more massive quantities of irresponsible E-waste exports to Asia. These pressures to export E-waste are increasing now that California and Massachusetts have banned the landfilling of CRT monitors and will increase even more if and when the EPA finally issues new regulations futher regulating E-wastes domestically.
While the U.S. government and industry may be acting irresponsibly, we as U.S. residents, small businesses, and consumers, can insist on another path. A way forward has been heralded by the European Union. These 15 European countries have already implemented the Basel Convention and have banned the export of all hazardous wastes to developing countries for any reason.
They have also readied legislation which will ensure that manufacturers are responsible for the entire life cycle of computers, are required to take computers and appliances back with the costs being born by the producers, and additionally, must agree to specific phase-out dates for toxic inputs. Japan also has taken steps to solve the problem by mandating upstream design criteria and mandatory take-back programs. Just as the U.S. is the largest impediment to the Basel treaty, the U.S. is also increasingly falling behind in the global efforts to bring about producer responsibility for life cycle impacts of products.
Now that we have seen the ugly face of the E-waste problem we must give the European model a second look.
Now that we have seen the ugly face of the E-waste problem we must give the European model a second look. We can no
Summary Findings
• Millions of pounds of electronic waste (E-Waste) from obsolete computers and TVs are being generated in the U.S. each year and huge amounts -- an estimated 50% to 80% collected for recycling -- is being exported.
• This export is due to cheaper labor, lack of environmental standards in Asia, and because such export is still legal in the United States.
• The E-waste recycling and disposal operations found in China, India, and Pakistan are extremely polluting and likely to be very damaging to human health. Examples include open burning of plastic waste, exposure to toxic solders, river dumping of acids, and widespread general dumping.
• Contrary to all principles of environmental justice, the United States, rather than banning exports of toxic E-waste to developing countries, is actually facilitating their export.
• China has banned the import of E-Waste and yet the United States refuses to honor that ban by preventing exports to them.
• Due to a severe lack of responsibility on the
part of the federal government and the electronics industry,
consumers, recyclers and local governments are left with few
viable, sustainable options for E-waste.
longer pretend that we don't know what is happening with a large portion of our discarded electronic waste. We can no longer allow its dumping on foreign shores. The real answer surely lies not in exporting our problems to those least able to deal with them, but in preventing the problems at their source.
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E-Waste
Just beneath the glamorous surface of the benefits and the wealth created by the information technology revolution looms a darker reality. Vast resource consumption and waste generation are increasing at alarming rates. The electronics industry is the world's largest and fastest growing manufacturing industry, and as a consequence of this growth, combined with rapid product obsolescence, discarded electronics or E-waste, is now the fastest growing waste stream in the industrialized world. The growing quantity of E-waste is beginning to reach disastrous proportions and industrialized countries all over the world are just now beginning to grapple with the problem. After initially turning a blind eye to the problem, governments of all sizes have been forced to respond as E-waste begins to seriously inundate solid waste disposal facilities and programs.
What is it?
E-waste encompasses a broad and growing range of electronic devices ranging from large household appliances such as refrigerators, air conditioners, hand-held cellular phones, personal stereos, and consumer electronics to computers.
E-waste has become a problem of crisis proportions because of two primary characteristics:
• E-waste is hazardous — E-waste contains over 1,000 different substances, many of which are toxic, and creates serious pollution upon disposal. Just some of the materials found in computers can be found in Annex I. A full discussion of the hazardous characteristics of E-waste is at the Hazards in E-Waste section of this report.
• E-waste is generated at alarming rates due to
obsolescence — Due to the extreme rates of obsolescence,
E-waste produces much higher volumes of waste in comparison to
other consumer goods. 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. Consumers now rarely take broken
electronics to a repair shop as replacement is now often easier and
cheaper than repair. The average lifespan of a computer has shrunk
from four or five years to two years.1 Part of this
rapid obsolescence is the result of a rapidly evolving technology.
But it is also clear that such obsolescence and the throw away
ethic results in a massive increase in corporate profits,
particularly when the electronics industry does not have to bear
the financial burden of downstream costs.
• Americans are buying more computers than people in any other nation. Currently over 50% of U.S. households own computers.2
• Data from single-day recycling collection events has revealed that more than 50% of turned-in computers are in good working order, but they are discarded nonetheless to make way for the latest technology.3
• By the year 2005, one computer will become obsolete for every new one put on the market.4
• In California alone, over $1.2 billion will be spent on E-waste disposal over the next five years.5
How Much E-Waste is There?
In 1998, it was estimated that 20 million computers became obsolete in the United States, and the overall E-waste volume was estimated at 5 to 7 million tons.6
The figures are projected to be higher today and rapidly growing. European studies estimate that the volume of E-waste is increasing by 3% - 5% per year, which is almost three times faster than the municipal waste stream is growing generally.7 Today, electronic waste likely comprises more than 5% of all municipal solid waste; that's more than disposable diapers or beverage containers, and about the same amount as all plastic packaging.
To make matters worse, solid waste agencies and recyclers are anticipating a major increase in the volume of computer and TV monitors discarded in the next 5 years. As cathode- ray tube (CRT) monitors currently in use will be replaced by smaller, and more desirable liquid crystal display (LCD) screens, this could mean massive dumping of CRT monitors at an even higher rate. Add to this the fact that new federal rules for high-definition televisions (HDTV) will become effective in 2004. This leap in technology is also expected to lead to a significant increase in television disposal.
A 1999 study conducted by Stanford Resources, Inc. for the National Safety Council projected that in 2001, more than 41 million personal computers would become obsolete in the U.S. Analysts estimate that in California alone more than 6,000 computers become obsolete every day.8 In Oregon and Washington, it is estimated that 1,600 computers become obsolete each day.9 Between the years 1997 and 2007, experts estimate that we will have more than 500 million
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obsolete computers in the United States.10 As this wave
of electronics surges into the waste stream, the environmental and
economic challenges will leave no community untouched.
computer about every three years.11 By law it is illegal for these large users to dispose of computers via landfill and thus, this E-waste goes to the re-use/recycling/export market.
Some large companies lease their computers from leasing companies, who take back working and non-working computers at the end of contracts. Leasing companies take out hundreds or thousands of computers at a time and in turn resell them to brokers in the reuse/export markets.
The volume of leased computers is huge in comparison to sales of new computers to corporations.12 Even the federal government is now getting into leasing rather than buying computerswhich by law they cannot send to landfills.13
Original equipment manufacturers (OEMs) — OEMs generate E-waste when units coming off the production line don't meet quality standards, and must be disposed of. Some of the computer manufacturers contract with recycling companies to handle their electronic waste, which often is exported. Other OEM's are major handlers of their own waste, e.g. Hewlett Packard who has two recycling facilities, in California and Tennessee. IBM has started its own recycling program in New York.
Where Does E-Waste Go?
The volume of obsolete computers thrown out or temporarily stored for later disposal is already a serious problem that is escalating at a rapid rate. Currently, and unfortunately, the vast majority of E-waste ends up in our landfills or incinerators. While there are efforts to divert E-waste from landfills, via "recycling", electronics "recycling" is a misleading characterization of many disparate practices _ including de-manufacturing, dismantling, shredding, burning, exporting, etc. _ that is mostly unregulated and often creates additional hazards itself. "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. Unless the goal is to redesign the product to use non-hazardous materials, such recycling is a false solution. Current market conditions and manufacturing methods and inputs discourage environmentally sound electronic recycling practices, so most E-waste that is currently being "recycled" is actually being exported, dismantled in prisons, or shredded in processes where there is some material recovery followed by the discard of the remaining materials.
Storage — U.S. government researchers estimate that
three-
How much waste is in 500 million computers?
Where Does E-Waste Come From?
Electronic waste is generated by three major sectors in the United States:
• individuals and small businesses
• large businesses, institutions, and governments
• original equipment manufacturers (OEMs).
Individuals and Small Businesses _ Electronic equipment, and computers in particular, are often discarded by households and small businesses, not because they are broken but simply because new technology has left them obsolete or undesirable. With today's computer industry delivering new technologies and `upgrades' to the market about every 18 months, the useful life-span of a personal computer has shrunk from four or five years down to two years. Often new software is incompatible or insufficient with older hardware so that customers are forced to buy new ones.
Due to legal exemptions in the definitions of solid and hazardous wastes, household and small business users are legally allowed to simply dump their computers into their trashcans for disposal in the local landfill or incinerator. The only exceptions to that so far are in California and Massachusetts where landfill bans have been passed. Thus, the present legal loophole makes landfill disposal preferrable. In fact, if a consumer goes to a recycler, they most likely will be charged a front-end fee (for monitors). By avoiding recyclers altogether, and simply throwing it in a dumpster, disposal of E-waste is no more costly than throwing away an orange peel.
Large corporations, institutions, and government _ Large users upgrade employee computers regularly. For example, Microsoft, with over 50,000 employees worldwide (some of whom have more than one computer) replaces each
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quarters of all computers ever sold in the United States remain stockpiled, awaiting disposal.14 Other studies estimate that the number of these unused, stored, computers in the U.S. will soon be as high as 315-680 million units.15 Consumers have, on average, a surprising 2-3 obsolete computers in their garages, closets or storage spaces.16 They often hang on to them in hopes that they will be worth something to someone someday. The value of computers decreases rapidly over time and will ultimately be worth only the value of the raw materials, less the cost to properly recycle them domestically. The residual value of old electronic equipment soon after production is 1-5% of the original cost of the equipment.17 Many consumers are unwilling to accept the fact that the latest system they paid top dollar for, just two or three years ago, is now largely worthless.
Landfill and Incineration _ According to the EPA, in 1997 more than 3.2 million tons of E-waste ended up in U.S. landfills. It is thought that most households and small businesses that dispose rather than store their obsolete electronic components send their material to landfills or incinerators rather than take them to recyclers.
All waste landfills leak. Even the best `state of the art' landfills are not completely secure and a certain amount of chemical and metal leaching will occur. The situation is far worse for the older or less stringently maintained dump sites. When disposed of in a landfill, E-waste becomes a conglomeration of plastic and steel casings, circuit boards, glass tubes, wires, resistors, capacitors, and other assorted parts and materials. About 70% of heavy metals (including mercury and cadmium) found in landfills come from electronic discards. These heavy metals and other hazardous substances found in electronics can contaminate groundwater.18 In 2001, CRTs were banned from municipal landfills in California and Massachusetts because of their recognized hazardous nature.
Municipal incinerators are some of the largest point sources for dioxins in the U.S. and Canadian environments and of heavy metal contamination of the atmosphere. Copper, common in E-waste, is a catalyst for dioxin formation. This is of particular concern as the incineration of brominated flame retardants and PVC leads to the generation of extremely toxic dioxins and furans and copper makes their formation more likely. Some producers send their E-waste to cement kilns for use as an alternative to fuel. But cement kilns present much the same problems posed by incinerators.
Re-use — Re-use constitutes direct second-hand use,
or use
after slight modifications are made to the original functioning
equipment—memory upgrades, etc . Re-use makes up a small
percentage (about 3% in 1998) of the computers that have been
discarded by their users. These computers are later sold in very
small numbers at some recycling stores or are given to schools, or
non-profit organizations. School districts that used to accept
older computers though, now demand more recent generation computers
for training students.
Foreign markets, on the other hand, have such cheap labor forces that they can buy working and non-working old computers, repair them at very little cost, and resell them for a profit. While there are no figures available, the amount of computers being exported for reuse is increasingly significant. While extending the usable life of a computer is a good thing, these older units obviously have a limited life span and will end up as waste sooner or later. Thus, these used computers will also end up as E-waste on foreign shores, often in countries that are least able to deal with them appropriately.
Domestic Recycling — All of the current information regarding E-waste recycling glaringly fails to point out that most of what is called E-waste recycling today involves recycling in a developing country. All of the studies that have been done fail to make a distinction between domestic recycling and recycling in developing countries with the gross assumption that all recycling is the same and all is equal from an environmental standpoint. The assumption too, is that recycling is always better than landfilling. This is not the case when the recycling results in toxic worker exposures, and the open dumping or burning of toxic residues and wastes that we have witnessed in Asia. While the recycling of hazardous materials anywhere creates a serious pollution challenge, it can be a disastrous one in an area of the world where the knowledge of, and infrastructure to deal with hazards and waste is almost non-existent.
With the cautionary note above, it is nevertheless estimated that in 1998, 11% of computers were being recycled (including those sent for export).19 And the amount is thought to be growing at about 18% per year.20 Thus, it is expected that 12.75 million computers (including monitors, and keyboards) will be recycled in 2002.21
Large corporations and manufacturers of new equipment tend to have a much higher rate of electronic waste recycling than individuals and small businesses because EPA regulations apply to much of this sector (unlike households and small business who are basically exempt from regulation). About 75 percent of end-of-life electronic products received by electronics recyclers come from new equipment managers and large-scale users (those with more than 500 employees).22 The corporate need to protect/destroy
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proprietary or confidential information on discarded computers provides another incentive for these large users to recycle; some recyclers offer specialty services that certify hard drives have been wiped clean.
It is very important to bear in mind that this very small percentage of E-waste now thought to be destined for recycling could increase dramatically with future state or federal legislation that might make it more and more difficult for small and household users to dispose of their waste in landfills. If legal restraints were placed on small users and households, the numbers of computers and E-waste diverted to recycling (and thus export) would grow dramatically (See the section on State of California for more about this).
After possibilities for re-use have been exhausted and a computer is slated for disposal, its worth in the marketplace will likely have been reduced from over 1,000 dollars to, very likely a negative value. Indeed most recyclers, due to the costs of dealing with the disposal of non-recyclable parts and the expense of dealing carefully with the toxic waste components of old computers, will not take your computer unless you are willing to pay them to take it.
While more recent model computers are valuable on the re-use market, the net worth of older computers at the point of disposal, not counting the costs of "recycling", is very small. For example, in an old computer: 5 pounds of steel could be worth $0.25; the central processing unit (cpu) with its gold tips and wiring (if the chip itself isn't worth anything on the re-use market) could be worth $1.00; the motherboard with its metal (gold, silver and copper) connectors - $2.00; cable (that are 30% copper in PVC sheaths) could be worth $0.09; the hard drive which is about 15% aluminum worth $0.10; and the monitor yoke which can be 60% copper is worth $0.80.23
In total, if it weren't for the fact that there are precious metals in computer electronic chips and boards, including silver, gold, platinum, and palladium, obsolete computers would be worth very little in today's recycling marketplace. For those with the technology to recover it, palladium is the most profitable. But many types of circuit boards (e.g. those found in monitors) have such low levels of precious metals that there is no domestic interest for them.
So, recycling the computers is often impossible without the
consumer subsidizing the recycler. For large commercial customers,
computer system leasors may negotiate lower prices for the
collection of obsolete computer systems. Individual customers
looking to recycle computers are left with far fewer options and
will likely have to pay a recycler
from $10-$30 per unit before they will be willing to accept it.
Households and small users are not required by law to manage their
E-waste as a controlled solid waste, and many consumers would
prefer to throw their old computers away rather than pay $10-$30
for recycling.
Prison — As an alternative to export to developing countries, there is another high growth area for E-waste emerging in the U.S. New "electronics recycling facilities" are opening in California and other states—in prisons. These recycling operations are touted as low-cost solutions to the E-waste problem. A brand new federal maximum security prison facility based in Atwater, California will occupy more than 50,000 square feet and will create 350 "jobs" dismantling computer monitors, televisions and other E-waste. It is being billed as the solution to California's crisis that has developed since the state Department of Toxic Substance Control banned cathode ray tubes from landfills last year. However, because of the low labor costs, domestic recyclers are concerned that they will not be able to compete. Others are concerned about the health and safety of prisoners working on the hazardous dismantling of monitors, since the federally prescribed occupational safety and health regulations of OSHA will not be applicable.24
Export to Developing Countries — The subject of this report is primarily about the most often overlooked and ignored E-waste management option _ export to developing countries under the name of "recycling". There are three primary reasons why E-waste is increasingly flooding Asian countries:
• The labor costs are very low (China $1.50 per day);
• Environmental and occupational regulations are lax or not well enforced; and
• It is legal in the U.S., despite international law to the contrary, to allow export of hazardous E-wastes with no controls whatsoever.
The issue of export of E-waste is the primary subject of this
report and will be further explored in the following sections.
Exporting Harm
8
Hazards In E-Waste
Although it is hardly well known, E-waste contains a witches' brew of toxic substances such as lead and cadmium in circuit boards; lead oxide and cadmium in monitor cathode ray tubes (CRTs); mercury in switches and flat screen monitors; cadmium in computer batteries; polychlorinated biphenyls (PCBs) in older capacitors and transformers; and brominated flame retardants on printed circuit boards, plastic casings, cables and polyvinyl chloride (PVC) cable insulation that release highly toxic dioxins and furans when burned to retrieve copper from the wires.
Due to the hazards involved, disposing and recycling E-waste has serious legal and environmental implications. When computer waste is landfilled or incinerated, it poses significant contamination problems. Landfills leach toxins into groundwater and incinerators emit toxic air pollutants including dioxins. Likewise, the recycling of computers has serious occupational and environmental implications, particularly when the recycling industry is often marginally profitable at best and often cannot afford to take the necessary precautions to protect the environment and worker health.
Lead25- The negative effects of lead are well established and recognized. It was first banned from gasoline in the 1970s. Lead causes damage to the central and peripheral nervous systems, blood systems, kidney and reproductive system in humans. Effects on the endocrine system have been observed and its serious negative effects on children's brain development are well documented. Lead accumulates in the environment and has high acute and chronic effects on plants, animals and micro-organisms.26 The main applications of lead in computers are: glass panels and gasket (frit) in computer monitors (3-8 pounds per monitor), and solder in printed circuit boards and other components.
Cadmium- Cadmium compounds are toxic with a possible risk of irreversible effects on human health, and accumulate in the human body, particularly the kidneys.27 Cadmium occurs in certain components such as SMD chip resistors, infra-red detectors, and semiconductor chips. Cadmium is also a plastics stabilizer and some older cathode ray tubes contain cadmium.
Mercury28 - Mercury can cause damage to
various organs including the brain and kidneys, as well as the
fetus. Most importantly, the developing fetus is highly susceptible
through maternal exposure to mercury. When inorganic mercury
spreads out in the water, it is transformed to
methylated mercury in the bottom sediments. Methylated mercury
easily accumulates in living organisms and concentrates through the
food chain, particularly via fish. It is estimated that 22 % of the
yearly world consumption of mercury is used in electrical and
electronic equipment. It is used in thermostats, sensors, relays,
switches (e.g. on printed circuit boards and in measuring
equipment), medical equipment, lamps, mobile phones and in
batteries. Mercury, used in flat panel displays, will likely
increase as their use replaces cathode ray tubes.
Hexavalent Chromium/Chromium VI29 - Chromium VI is still used as corrosion protection of untreated and galvanized steel plates and as a decorative or hardener for steel housings. It easily passes through cell membranes and is then absorbed— producing various toxic effects in contaminated cells. Chromium VI can cause damage to DNA and is extremely toxic in the environment.
Plastics including PVC - Plastics make up 13.8 pounds of an average computer. The largest volume of plastics (26%) used in electronics has been poly-vinyl-chloride (PVC). PVC is mainly found in cabling and computer housings, although many computer moldings are now made with the somewhat more benign ABS plastics. PVC is used for its fire-retardant properties. As with many other chlorine-containing compounds, dioxin can be formed when PVC is burned within a certain temperature range.
Brominated flame retardants (BFRs) - BFRs are used in the plastic housings of electronic equipment and in circuit boards to prevent flammability. More than 50% of BFR usage in the electronics industry consists of tetrabromobisphenol _ A (TBBPA), 10% is polybrominated diphenyl ethers (PBDEs) and less than 1% is polybrominated biphenyls (PBB).30 Some BFRs have been targeted for phase out by the European Parliament between the years of 2003 and 2006.
Barium - Barium is a soft silvery-white metal that is used in computers in the front panel of a CRT, to protect users from radiation . Studies have shown that short-term exposure to barium has caused brain swelling, muscle weakness, damage to the heart, liver, and spleen.31 There is still a lack of data on the effects of chronic barium exposures to humans. Animal studies, however, reveal increased blood pressure and changes in the heart from ingesting barium over a long period of time.
Beryllium - Beryllium is a steel-grey metal that is extremely lightweight, hard, a good conductor of electricity and heat, and is non-magnetic. These properties make
Exporting Harm
9
beryllium suitable for many industrial uses, including, electronic
applications such as computers. In computers, beryllium is commonly
found on mother-boards and "finger clips" as a copper beryllium
alloy used to strengthen the tensile strength of connectors and
tinyplugs while maintaining electrical conductivity.
Beryllium has recently been classified as a human carcinogen as exposure to it can cause lung cancer.32 The primary health concern is inhalation of beryllium dust, fume or mist. Workers who are constantly exposed to beryllium, even in small amounts, and who become sensitized to it can develop what is known as Chronic Beryllium Disease (beryllicosis), a disease which primarily affects the lungs.33 Exposure to beryllium also causes a form of skin disease that is characterized by poor wound healing and wart-like bumps.34 Studies have shown that people can still develop beryllium disease even many years following the last exposure.
Toners - One of the ubiquitous computer peripheral scraps and post consmuer E-waste is the plastic printer cartridge containing black and color toners. The main ingredient of the black toner is a pigment commonly called, carbon black35 - the general term used to describe the commercial powder form of carbon. Inhalation is the primary exposure pathway, and acute exposure may lead to respiratory tract irritation.36 The International Agency for Research on Cancer has classified carbon black as a class 2B carcinogen, possibly carcinogenic to humans.37 Little information exists on the hazards of colored toners. Some reports indicate that such toners (cyan, yellow and magenta) contain heavy metals.
Phosphor and additives - Phosphor is an inorganic chemical compound that is applied as a coat on the interior of the CRT faceplate. Phosphor affects the display resolution and luminance of the images that is seen in the monitor. The hazards of phosphor in CRTs are not well known or reported, but the U.S. Navy has not minced words about the hazards involved in some of their guidelines: "NEVER touch a CRT's phosphor coating: it is extremely toxic. If you break a CRT, clean up the glass fragments very carefully. If you touch the phosphor seek medical attention immediately."38 The phosphor coating contains heavy metals, such as cadmium, and other rare earth metals, e.g. zinc, vanadium, etc. as additives. These metals and their compounds are very toxic. This is a serious hazard posed for those who dismantle CRTs by hand.
Some recyclers in the United States are not happy with the idea that so much of the E-waste generated is currently exported off-shore to Asia. Many got into the recycling business to help find solutions to problems created by our consumption habits.
Mr. Craig Lorch of Seattle's Total Reclaim, is one who got into the business as both an environmentalist and a businessman. Total Reclaim entered into a cooperative agreement with King County in Washington State to provide a mechanism to try and prevent the leaded CRTs in computer monitors from entering landfills. Total Reclaim breaks down monitors and crushes the leaded glass. Thereafter, the glass is sent to Envirocycle in Pennsylvania to be cleaned and used as feedstock in the manufacture of new CRTs. While Lorch has developed a strategy to manage the leaded CRT glass domestically, he has little alternative but to sell the circuit boards,plastics, wires and cables to scrap brokers who are very likely to export them depending on the global market.
"I don't want to see this stuff exported to developing countries and I think there are a lot of recyclers out there like me. But with no domestic markets for material and no regulations against export, I'm afraid its going to happen…and ultimately it does not really solve the serious issues -- it merely sweeps these issues under the carpet. We can do better than that."
Lorch provides true domestic recycling for CRTs and is the only such outlet in the Washington State area. He is frustrated that not all local area recyclers care to utilize available domestic solutions even when they are available, but simply export the monitors.
"Right now, the economics of electronics recycling
clearly prefers export over managing the material in the U.S. Every
day we must make the choice between spending money to disassemble
and manage the material here or simply load it into a shipping
container and sell it offshore. Why would a good business person
allow spending 3 to 4 dollars to disassemble and handle material
domestically when the same material can be sold offshore for 3
bucks. It's a 6 dollar swing -- that's a make or break difference
for a recycler."
Exporting Harm
10
One of the primary reasons why the United States lags behind the rest of the world in grappling with the growing E-waste crisis is due to the fact that they, and other rich industrialized countries, have made use of a convenient, and until now, hidden, escape valve _ the export of the E-waste crisis to the developing countries of Asia.
Rich industrialized countries have made use of a convenient, and until now, hidden escape valve _ the export of the E-waste crisis to the developing countries of Asia.
The overwhelming majority of the world's hazardous waste is generated by industrialized market economies. Exporting this waste to less developed countries has historically been one way in which the industrialized world has avoided having to deal with the problem of expensive disposal and close public scrutiny at home. Indeed, the world faced a rash of blatant waste trade scandals in the late 1980's and early 1990's. These were largely quelled by public pressure and the passage of international law, such as the Basel Convention.
Now, however, we are seeing a new wave of the waste trade which is often justified by calling it recycling. This waste trade often involves post-consumer wastes such as old ships laden with asbestos and other toxins sent for breaking in South Asian countries, or now, as we have discovered, hazardous electronic wastes sent for dirty "recycling" operations in Asia.
Like most waste trade, E-waste exports to developing countries are motivated entirely by brute global economics. Market forces, if left unregulated, dictate that toxic waste will always run "downhill" on an economic path of least resistance. If left unchecked, the toxic effluent of the affluent will flood towards the world's poorest countries where labor is cheap, and occupational and environmental protections are inadequate. A free trade in hazardous wastes leaves the poorer peoples of the world with an untenable choice between poverty and poison _ a choice that nobody should have to make.
Now we are seeing a new wave of waste trade often justified by calling it recycling. This waste trade often involves post-consumer wastes such as hazardous E-wastes sent for dirty "recycling" operations in Asia.
It was in an effort to counter the unsustainable and unjust
effects of free trade in toxic wastes, that an international
treaty
known as the Basel Convention was created in 1989. And it was also
for this reason that the Basel Convention in 1994 agreed to adopt a
total ban on the export of all hazardous wastes from rich to poor
countries for any reason, including recycling (see section on Basel
Convention).
There are two fundamental reasons for banning the economically motivated trade in hazardous wastes:
· Downstream Impacts: Hazardous waste trade is fundamentally unjust and environmentally damaging since it victimizes the poor, burdening them with toxic exposure and environmental degradation. This is especially egregious when the victims get little benefit from the industrialization that created the waste in the first place.
· Upstream Impacts: Hazardous waste trade allows waste generators to externalize their costs, creating a major disincentive to finding true solutions upstream for the problems they create. As long as one can cheaply dump their waste problems on poorer economies, there will never be incentives to minimize hazardous waste at the source. This forestalls the necessary innovation to solve environmental problems through design.
The latter reason is extremely important and comes into play even if the recipient country possesses a so-called state-of-the-art hazardous waste recycling facility. No hazardous waste recycling facility is without its toxic impacts, residues, emissions and worker exposure. It is a risky and polluting enterprise even in optimal conditions. The ultimate answer is to miminze the generation of hazardous wastes, not recycle them. Yet via economically motivated export, the preferable goal of zero hazardous waste generation will be forestalled.
The U.S. failure to join the consensus of the international community in condemning waste trade has enabled the U.S. electronics industry to continue a head-in-the-sand, business-as-usual, for-as-long-as-possible approach, with little incentive to aggressively pursue greener product design and producer responsibility.
Consumers may be very surprised to know that most companies that call themselves recyclers of computers and E-waste often do more waste trading than actual waste recycling, either directly or indirectly. Informed industry insiders have indicated that around 80% of what comes through their doors will be
Exporting Harm
11
exported to Asia, and 90% of that has been destined for China. And as recycling rates are expected to increase 18% per year, we can also expect the amount going for export will increase at that rate as well.
…Industry insiders have indicated that around 80% of what comes through their doors will be exported offshore to Asia and 90% of that will go to China.
Typically a computer recycler will "high-grade" incoming material _ that is skim the most valuable components off of the pile and possibly sell them in a store or to specialty brokers. The rest of the material may be broken down and sorted according to the type of waste (e.g. circuit boards, wires and cables, plastics, CRTs, and non-recyclables) and thrown into large cardboard boxes (or gaylords). These gaylords are then sold to brokers who arrange the shipping via container to Asia. In China, the containers arrive at the port of Nanhai, near Hong Kong in Guangdong Province where it is reported there are 4 large warehouses. The warehouses subsequently "high-grade" again and sell accordingly in the Chinese market.
Alternatively, an E-waste broker may simply take the material in bulk and ship it off to Asia as-is with no separation whatsoever. E-waste brokering is an aggressive and very competitive business, and it is not difficult to find buyers for all kinds of E-waste for the Asian market (see a typical solicitation in Annex V). The largest market of non-working equipment is for the circuit boards that are rich in precious metals, i.e. silver, gold, palladium and platinum.
As Craig Lorch of Total Reclaim, a recycler in Seattle who tries
to avoid export, described the waste brokerage business: "I
think it's about the money. When you move material offshore, you
get paid twice for doing very little work. You get paid on the
front side for taking somebody's material and you get paid on the
backside for getting rid of it to Asia, and
you don't do a whole lot of work for it, so its all about the
money."38
A pilot program conducted by the U.S. 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 U.S.39
"I think it's about the money. When you move material offshore, you get paid twice for doing very little work. You get paid on the front side for taking somebody's material and you get paid on the backside for getting rid of it to Asia"
Domestic "electronics recycling" is currently more a wish than a reality. Computers are not really designed for ease of recycling, and thus, their dismantling is extremely labor intensive. Further, the existence of toxic components in the waste poses a significant risk to recyclers and, increasingly, the disposal of these components and residues from recycling are more and more costly to manage. Further, obtaining access to the valuable materials that are contained in E-waste _ especially metals like copper or gold _ is difficult because it is bound up in plastics and mixed with other contaminates that makes it expensive to separate. Environmentally appropriate recycling facilities that handle leaded glass, mixed plastics, lead solder in circuit boards, etc. are now very limited in the United States.
In short, computers and electronic equipment are designed with
little regard for downstream impacts and ease of recycling. Thus to
date, very little economical recycling is taking place in a rich,
developed country like the United States. Without the end-of-life
costs being incorporated into the upfront price of new products,
the only economically viable recycling that can take place is in an
economy far different from the economy in which it most likely was
consumed, utilized and enjoyed. Most E-waste will only
Exporting Harm
12
have positive value in a poor developing country where labor costs might be $1.50 per day and environmental and health standards are lax or not enforced. But this grim reality, in a free market, will mean that the poor of the world will be forced to bear a disproportionate share of the E-waste environmental burden. This current reality is the dirty little secret of the electronics industry.
Finally, it must be remembered that as long as the U.S. recyclers are competing with the low costs of Asian recycling, it is unlikely that there will be sufficient incentives to invest in the necessary infrastructure forward to efficiently and safely recycle E-wastes in this country, such as through the purchase of computer shredders and material separators which might be able to more completely handle the complex mix of materials that make up electronic equipment.
Discussions with United States officials reveal the U.S. position on E-waste export. Their hopes rest in the misguided notion that all that is necessary to justify export to developing countries is to improve their standards and operating procedures. But this idea conveniently fails to comprehend realities in developing countries. Does a typical developing country really possess the resources and infrastructure to monitor and maintain the technology? Does the regulatory infrastructure allow for the protection of workers and community rights? Are there sufficient rights of citizens to sue for damages caused to their health, environment and property? There is so much more involved in environmental and health protection than mere turn-key technology.
The U.S. failure to join the consensus of the international community in condemning waste trade has enabled the electronics industry based here to continue a head-in-the-sand, business-as-usual approach, with little incentive to aggressively pursue greener product design and producer responsibility.
We have also heard argumentation that insists that because
electronics are increasingly manufactured in Asia, then export of
these waste materials back to Asia once they become waste back to
Asia makes some kind of sense from either a moral or environmental
standpoint. We have even heard justifications of waste export to
Asia as a twist on the "take-back" argument. This argumentation is
seemingly compelling to those wishing to justify waste
exports, but the professed logic falls apart quickly on closer
examination.
The mere fact that cheap labor is exploited once by a transnational electronics 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. Already the high-tech industry has become notorious for creating toxic jobs and toxic pollution in Asian manufacturing operations. It is the height of cynicism to claim that therefore they might see more of the same _ particularly when the benefits of most of the high-tech products are enjoyed in rich developed countries.
Take-back must occur in the country and area of consumption to minimize cross-border economic dumping and unnecessary transport.
The concept of producer responsibility is aimed at applying pressure to corporate leadership that can affect design and corporate policy. This leadership is rarely found at production operations in developing countries in Asia. Take-back programs should not be new justifications for the transboundary movements of wastes, particularly to developing countries. Rather, the take-back must occur in the country and area of consumption to minimize cross-border economic dumping and unnecessary transport.
Finally, we have heard arguments that suggest that exporting
obsolete computers for refurbishing and re-use in Asia is laudable
as it adds extra life to the product and provides those more needy
with a way to cross the digital-divide. While we can understand
such justification for export, it must be fully understood that
even when working computers are exported to Asia, they will in fact
end their life cycle in Asia. In other words, the day when obsolete
electronic products in the U.S. become hazardous E-waste on Asian
soil is simply forestalled by some months or a few years. The
environmental and justice impacts from the export will be the same
_ the United States will still have moved its toxic E-waste problem
to Asia.
Exporting Harm
13
Department of Commerce representative replied, "There aren't
any."42
How much E-Waste is Exported?
The short answer is that nobody really knows. Yet anecdotal evidence on E-waste exported by the U.S. 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. What cannot be recycled readily or economically in
The U.S. government utilizes the global Harmonized Tariff Sys-tem (HTS) to monitor the millions of import and export tran-sactions occurring within its borders. Under the HTS, tran-sactions are classified under approximately 8,000 product categories. But none of these categories corresponds to com-puter or electronic waste. Rather, whenever a shipment of E-waste occurs, it is included under the HTS category for new computers and electronics.43 Thus, the trade data for the export of new computers includes the data for obsolete computers. Until this serious problem with the HTS is cor-rected, the U.S. will have inadequate data regarding waste exports. For some, this institutionalized ignorance is a blissful one.
There are, however, some serious studies which provide estimates of the amount of U.S. computers that go or will go to recyclers each year. One such study compiled by the Graduate School of Industrial Administration of Carnegie Mellon University, concludes that in the year 2002, 12.75 million computer units will go to recyclers in the U.S.44
Based on this estimate, and with a rate of 80% moving offshore
to Asia, the total amount would equate to 10.2 million units. This
is the equivalent of a tightly stacked pile of computer waste one
acre square and 674 feet high -- a height easily covering the
Seattle Space Needle or more than twice the height of the Statue of
Liberty from ground to torch. If we were to calculate a
conservative figure of 50% diversion to Asia, we could expect a
solid stack of computer waste one acre square and lifting to a
height of 421 feet. It must be remembered that this is for only one
year and one source country.
Just some of the many institutional labels from the United
States found on computers in Guiyu, China in, December 2001.
© BAN
the United States is often sold to brokers that look for the best price on the global market. Very often that best price will be found in Asia where labor costs are cheap and environmental and health protections minimal. Very knowledgable and informed industry sources, however, have estimated that around 80% of what is diverted to recycling is actually exported to Asia.41
The U.S. government has no idea how much E-waste is exported
from their territory or where it goes. When asked directly about
the existence of such data, the U.S.
China: The Story of
Guiyu
In December of 2001, the Basel Action Network (BAN), with the logistical support of Green-peace China in Hong Kong, conducted an investigation to observe first hand, the recycling conditions of imported E-waste in China. In the course of three intensive days, the investigatory team conducted interviews, shot video and still photographs, and took spot sediment, soil and water samples near and within the town and vicinity of Guiyu, located about an hour's drive west of Shantou City in the Chaozhou region of the greater Guangdong Province.
Very typical on-street E-waste dismantling operation in Guiyu. Using hammers and chisels and their bare hands, workers separate the waste into aluminum, steel, copper, plastic and circuit boards. © BAN
The investigation does not
purport to be a comprehensive one, and we do not claim that what
we witnessed was representative of all E-waste recycling in China.
Rather, it must be seen as one view _ and perhaps a view of the
"tip-of-an-iceberg." We do not know if Guiyu is the only E-waste
processing center in China, nor do we know if other centers, should
they exist, are similar in scale and type of operation to what we
witnessed. We were told that in Nanhai, and perhaps in Guangzhou,
other operations also exist, perhaps of larger scale and employing
hundreds of workers each. We were also told that in Guangzhou there
are operations that include the resale of used parts and the
renewal of computer parts to manufacture as "new" computers.
A Community Transformed
"For money, people have made a mess of this good farming
village. After they have dismantled the computers, they burn the
useless parts. Every day villagers inhale this dirty air; their
bodies have become weak. Many people have developed respiratory and
skin problems. Some people wash vegetables and dishes with the
polluted water, and they get stomach sickness."
-- Mr. Li who has lived in
Huamei village for 60 years.45
The entire Guiyu area is actually made up of four small villages which lie along the Lianjiang River: Huamei Village, Longgang Village, Xianpeng Village, and Beilin Village (which we will refer to collectively as "Guiyu").
Since 1995, Guiyu has been transformed from a poor, rural,
rice-growing community to a booming E-waste processing center.
While rice is still grown in the fields, virtually all of the
available building space has given way to providing many hundreds
of small and often specialized E-waste recycling shelters and
yards. The types of waste and processing are often segregated, with
one neighborhood, for example, involved in dismantling printers
while another might process recovered plastics.
Along with the new E-waste recycling business has come serious environmental and occupational impacts, some of
Drinking water is routinely transported to Guiyu from Ninjing due to severe groundwater pollution. © BAN
which are accepted by the population and work force while other chronic toxic impacts are unnoticed as the public is unaware of the hidden threat. The likely health and environmental implications from this new industry are discussed elsewhere in this report.
One impact that has not gone unnoticed has been the
deterioration of the local drinking water supply. The E-waste
industry in Guiyu has been going for six years; for the last 5
years, due to groundwater pollution, water has had to be trucked in
from the town of Ninjing, 30 kilometers away. The local residents
claim that the water has become foul tasting. It is unknown whether
the government has warned the public not to drink it. But in any
case, a new business has developed with a constant parade of
tractors carrying large plastic tanks of fresh water into Guiyu
every day.
Typical truckload of E-waste purchased from Nanhai for scrapping in Guiyu. © BAN
Waste Origins
The relatively small scale of the many individual operations
belies the magnitude of the operations multiplied in their
totality. After three days of driving about Guiyu and its many
back-streets and neighborhoods, we did not even come close to
seeing all of the operations. Chinese press accounts placed the
total employed in the E-waste sector in Guiyu at 100,000; but it
would be a very difficult number to estimate, due to a fluctuating
migrant workforce.
Due to the institutional labels, markings, maintenance stickers and
phone numbers on the computers and peripheral units, it was very
easy to determine the source of the E-wastes. Most of the material
was clearly of North American origin, with Japanese, South Korean
and European waste witnessed to a lesser degree.
Each business in Guiyu operates at a fairly small scale.
Operators are able to purchase just single truckloads at a time.
These trucks ferry the E-waste from what is reported to be four
large warehouses in the port of Nanhai (see map) where the imported
waste arrives in sea-going containers. The trucks used for the
five-hour transport to Guiyu are smaller than sea-
Most of the labor force working in the recycling operations comes
from outlying agrarian regions. The former farmers migrate to Guiyu
from provinces such as Hunan or Anhui to take the menial jobs of
dismantling and processing the imported E-waste for an average wage
equivalent to $1.50 per day. Many of the workers are women and
children.
It is also virtually impossible to estimate how much E-waste is
processed there annually. However, the anecdotal observation is one
of very high turn-over with hundreds of trucks moving in and out
daily, and a steady rumble and buzz of activity. These observations
led us to conclude that Guiyu is a very significant destination for
the world's E-waste.
Map depicting the location of Guiyu in the Chaozhou region of
Guangdong Province. Most of the E-waste arrives by sea-going
containers via ships at the port of Nanhai. © BAN
Exporting Harm
16
going containers. However, the waste clearly comes unsorted from
the same containers, as the institutional labels, phone numbers and
other geographic markers remain consistent with each truckload.
indicate that although carbon black and other black toner
ingredients are not toxic per se, they will cause lung and
respiratory irritation. Other documentation claims that carbon
black is a possible human carcinogen. No reference indicating what
chemicals are present in color toners has been found. The MSDS
sheets are careful to note that under normal use the black
toners will cause no health problems. Clearly what takes place in
Guiyu is not normal use.
The Recycled Materials
Most of the activity in Guiyu involves physical dismantling by hammer, chisel, screw driver and bare hand. The most high- tech piece of dismantling equipment witnessed was an electric drill. The immediate objective of most of the operations involve dismantling -- the rapid separation of primary materials. The following materials were observed being separated for further recycling:
• Material containing copper: Including printer and other motors, wires and cables, CRT yokes.
• Steel: Including internal computer frames, power
supply housings, printer parts, etc.
• Plastic: Including housings of computers, printers, faxes, phones, monitors, keyboards, etc.
• Aluminum: Printer parts, etc.
• Printer Toner: From spent toner cartridges
• Circuit Boards: These come from many applications including computers, phones, disc drives, printers, monitors, etc. These boards were subject to further separation in other facilities as follows:
Worker without respiratory protection brushing carbon-black toner from printer cartridge into bucket. © BAN
Open Burning
In the process of dismantling computers, a considerable amount of material is collected and dumped outside of town along the river where much of the dirtier operations of Guiyu take place. There, a small village has stood (for two years now) where the residents make their living entirely by burning these wires to recover copper. The village exists in a landscape of black ash residue which covers the ground and the houses of the village. The burning always takes place in the middle of the night, indicating that local authorities have likely frowned upon the black smoke plumes.
• Valuable reusable processors and chips: for
resale
• Other chips and connectors containing gold: for acid processing
• Solder: (lead/tin base) for resale
Hazardous Recycling Operations
Toner Sweeping
Certain areas of Guiyu are dedicated to printer dismantling. In
those areas the operations strictly deal with toner cartridges _
both black as well as the cyan, magenta and yellow toners of color
copiers and printers. We observed that the only recycling taking
place involved the small amounts of residual toner, with the black
cartridge plastic largely discarded. Workers without any protective
respiratory equipment or special clothing of any kind opened
cartridges with screw drivers and then used paint brushes and their
bare hands to wipe the toner into a bucket. The final end-use of
the recovered toner is uncertain. The process created constant
clouds of toner that billowed around the workers and was routinely
inhaled. In the course of the day, the worker's skin and clothing
was blackened. Material Safety Data Sheets (MSDS) provided by Xerox
and Canon
Child of wire-burning village eating an apple in his "backyard" playground -- a landscape of ash and toxic residues. © BAN
Exporting Harm
17
this food source is contaminated from the pollution.
CRT Cracking and Dumping
Prior to leaving for China we had heard reports that cathode-ray
tubes (CRTs) from computer monitors and televisions were sold to
China for refurbishing into "new" television sets or computers.
Un-fortunately, this is not what was witnessed in Guiyu. Rather,
invariably we saw the copper-laden yokes from the end of the tube
broken off with the CRT itself being cracked and discarded in the
process. We were informed that the yokes were sold to copper
recovery operations.
Living on ash: Wire-burning village where the residents sort
wires by day and burn wires by night. © BAN
It is extremely likely that due to the presence of PVC or
brominated flame retardants in wire insulation, the emissions and
ashes from such burning will contain high levels of both brominated
and chlorinated dioxins and furans _ two of the most deadly
persistent organic pollutants (POPs). It is also highly likely that
cancer-causing polycyclic aromatic hydrocarbons (PAHs) are also
present in the emissions and ash.
Yet about 100 people live in the village, including pregnant women. Scores of small children play among the ash heaps. Drinking, cooking and washing is done with local ash-contaminated surface waters. Additionally, the village lies adjacent to two fish ponds which provide the villagers with their food and protein supply. It is extremely likely that
Open burning of wires and other parts are common to recover
metals such as steel and copper. Dioxins and furans can be expected
due to the use of PVC and brominated flame retardants.
© BAN
Broken CRTs awaiting land disposal after the copper yoke has
been removed in Guiyu, China. © BAN
Close-up of computer wires prior to burning. ©
BAN
Exporting Harm
18
in this endeavor. They place the circuit boards on shallow wok-like
grills that are heated underneath by a can filled with ignited
coal. In the wok-grill is a pool of molten lead-tin solder. The
circuit boards are placed in the pooled molten solder and heated
until the chips are removable. These are then plucked out with
pliers and placed quickly in buckets.
Dismantler cracking a monitor to remove the copper yoke. The
rest of the CRT is dumped. © BAN
In any case, the lead-laden monitor glass, which qualifies as a
hazardous waste in the Basel Convention and fails U.S. EPA's
leachate tests (TCLP), was regularly dumped on open land or pushed
into rivers. In Guiyu itself, a former rice-growing village, the
ancient granite-lined irrigation canals were routinely filled with
the broken monitor glass and other un-recycled plastic E-waste.
Once these were filled, bulldozers were brought in to push the
material out into trucks to be hauled away elsewhere. It is likely
that this routine dumping of monitor glass is at least partially
responsible for the severe well-water pollution.
Piles of de-soldered circuit boards, ubiquitous in Guiyu, await
hauling to a dump or riverside to be burned. © BAN
Circuit Board Recycling
It is likely that the most environmentally destructive recycling overall involves the recovery of the various components and materials found on electronic circuit boards. While there are differing approaches practiced around Guiyu, the general approach to recycling a circuit board involves first a de-soldering process. Many hundreds of workers, usually women and girls, are active each day
Laborer de-soldering circuit boards over a coal-fired grill.
Rock in the box is where boards are hit to remove solder. Pliers
are used to pluck off chips which go into various buckets. The
boards are then tossed into a pile for open burning. ©
BAN
Exporting Harm
19
Solder is also collected by slapping the boards hard against
something such as a rock where the solder collects and is later
melted off and sold. While there are sometimes fans placed to blow
the toxic lead-tin solder fumes away, the exposure on a daily basis
is likely to be very damaging to the laborers' health.
The removed chips are then separated between those valuable for re-sale and those to be sent to the acid chem-ical strippers for gold recovery. Often the pins on chips will be straightened and later dipped in fresh solder to make them look new for use in the computer refabrication business, said to be prominent in Guangzhou.
After the de-soldering process, the stripped circuit boards might go to another less skilled laborer who then removes
small capacitors and other less valuable components for
separation with wire clippers. After most of the board is picked
over, it then goes to large scale burning or acid recovery
operations outside of town along the river where the last remaining
metals are recovered. Whole riverbanks were seen full of charred
circuit boards reduced to blackened fiber-glass. This final burning
process is bound to emit substantial quantities of harmful heavy
metals, dioxins, beryllium and PAH's. Some of the severely
contaminated areas we sampled are adjacent to areas where circuit
boards were burned (see Annexes II and III).
Acid Stripping of Chips
Much of the work to remove chips from circuit boards is done for
the ultimate purpose of removing precious metals. This is most
often done by a very primitive process using acid baths. Although
we could not test the actual chemicals, after talking with
metallurgical experts, we are confident that the baths were in fact
aqua regia (a mixture of
Laborer heating aqua regia acid mixture along riverside chemical
stripping operation to extract gold from imported computer chips.
All waste acids and sludges are dumped into the river. The only
protective equipment used are rubber boots and gloves.
© BAN
25% pure nitric acid and 75% pure hydrochloric acid. This
mixture and process was invariably applied directly on the banks of
rivers and waterways. The aqua regia was first
Another gold extraction operation utilizing aqua regia on the
banks of another river near Guiyu. © BAN
small fires and then poured into plastic tubs full of computer
chips. These in turn were routinely swirled and agitated to
dissolve the tiny amounts of gold found inside. After many hours of
this, a chemical is then added which precipitates the gold, making
it settle to the bottom of the tub. This is
Laborer swirling aqua regia acid over computer chips to extract
gold. © BAN
Exporting Harm
20
recovered as a mud, dried, and then finally melted to a tiny bead
of pure, shiny gold.
The process resulted in huge clouds of steamy acid gases being emitted, which looked like smoke from even far away. Worse, the process resulted in the routine dumping of aqua regia process sludges that blackened the river banks with the resinous material making up computer chips. A quick test using pH paper of the saturated ground surrounding the tubs measured at a pH level of 0 -- the strongest level of acidity.
The men worked at this process day and night protected
only by rubber boots and gloves. They had nothing to
protect them from inhaling and enduring the acrid and
often toxic fumes. The aqua regia process is known
to emit toxic chlorine and sulphur dioxide gases.
Plastic computer housings separated and stacked to go to where it all is melted down for low quality further use plastics. © BAN
whether or not it would be possible to filter out the dangerous
hydrocarbons including the dioxins and furans that are likely to be
produced when melting brominated flame retardant impregnated
plastic or PVC plastic.
Despite the attempt to recycle much of the plastic from the E-waste
stream, it was clear that a large percentage was deemed
unrecyclable due to impurities or the difficulty in separating it,
or matching the colors. The result of this was that many, many tons
of plastic E-waste was seen in countless piles dumped throughout
the landscape and most often near waterways.
Materials Dumped
A tremendous amount of imported E-waste material and process residues are not recycled but simply dumped in open fields, along riverbanks, ponds, wetlands, in rivers,
Plastic chipper (foreground) and melter unit behind being
operated without respiratory equipment. The operation melts down
computer plastics possibly impregnated with brominated flame
retardants -- likely creating dioxins. © BAN
Plastic Chipping and Melting
The plastic parts of E-waste, and in particular the housings of computers, monitors, and plastic keyboard parts, etc. were all sent to one of the Guiyu villages that was preoccupied with processing plastics.
Much time is spent there, chipping plastics into small particles, and then separating the various colors of plastics so that a clean colored remelt would be possible. Often children are employed for this tedious job. Then the chips are bagged and sent to melting and extruding oper-
ations. The melting of the computer plastics is done in rooms with little ventilation and with no respiratory protection. It is not even known if such protection were to be used,
Children sorting out tiny specks of wrong colored plastic chips. Many hundreds of bags await their eyes and fingers. © BAN
Exporting Harm
21
and in irrigation ditches. These materials include leaded CRT
glass, burned or acid-reduced circuit boards, mixed, dirty plastics
including mylar and videotape, toner cartridges, and considerable
material apparently too difficult to separate. Also dumped are
residues from recycling operations including ashes from numerous
open burning operations, and spent acid baths and sludges. It is
this indiscriminate dumping which has no doubt led to the severe
contamination of the drinking water supply of Guiyu. Although we
are not aware of whether or not the government has conducted tests
of the groundwater or local sediments, BAN did take some samples
along two rivers which we analysed.
Irrigation canal now used for CRT glass dump.
© BAN
Sediment and Water Sample Results
times the threshold WHO level. This likely demonstrates that the sediment and soil remain saturated with pollution.
Sediment samples were also astonishingly contaminated. A sediment
sample taken near the above river location, showed lead 212
times higher than what would be treated as hazardous waste had
it been dredged from the Rhine River bottom in the Netherlands.
Likewise other heavy metals found in circuit boards and in CRTs
were found in very high quantities. Barium was found at levels
almost 10 times higher than an EPA threshold for environmental risk
in soil. Tin was found at levels 152 times the EPA threshold.
Chromium in one sample was at levels 1,338 times the EPA threshold
level. And copper in another sample (which in fact appeared to be a
dumped residue from some recycling process found on the banks of a
river) was an astounding 13.6% of the total.
Of course these spot samples cannot provide a comprehensive view
of the contamination levels of Guiyu and environs. It is imperative
therefore that serious data be
The investigative team took one water sample, one sediment sample,
three soil samples in one area along the Lianjiang River where
circuit boards had been treated with acid and fire and then were
dumped charred along the banks. A year previously, in 2000, a Hong
Kong reporter from Eastweek Magazine, a Chinese language journal,
had visited the very same site when operations there were active.
After the publication, the government halted the operations in that
locale.
All of the test results taken by BAN and the reporter were analyzed by the Hong Kong Standards and Testing Centre Ltd. Later, BAN took one more sample in another location along the Lianjiang River downstream from where wires were routinely burned.
The test results revealed alarming levels of heavy metals that correspond very directly with those metals most commonly found in
computers (see Annex II and III).
The single water
sample taken by the
reporter in 2000 adjacent to a location where circuit boards
had been processed and burned in the past, revealed lead levels
that were 2,400 times higher than World Health Organiz-ation
(WHO) Drinking Water Guidelines. In December of 2001, when BAN
visited the site, the levels were found to still be 190
Dump of acid treated circuit boards and processing residues
along the Lianjiang River. © BAN
gathered on both human and environmental
health in the region. Rather, these samples reveal that in some
locations, Guiyu is very seriously polluted, and signal an urgency
to find out how widespread the problem really is, and how far it
has impacted the health of the community and its residents.
Exporting Harm
22
India and Pakistan
primary pre-distribution centers between Europe and South Asia. Another of these is Singapore. Pakistani businessmen purchase the E-waste from Dubai and forward it to Karachi in sea-going containers. Typical costs of scrap purchase in Dubai is around 35-40 Pakistani Rupees (PKR) (65 US cents) per kilogram, including all expenses, whereas costs from Singapore were reported as being around PKR 200 or (US $3.27) per kilogram.
After reaching the port, custom officials scatter the waste out and put duty on various items according to their value and use. Thereafter the material is brought to large warehouses. Other than the duty officers, there is no authority to question the import or subsequent recycling and
Very preliminary investigations in both Pakistan and India
reveal that these countries are receiving and processing western
originated E-waste in similar processes to what was observed in
China. It is clear from these first glimpses of operations in these
two South Asian countries that that the migration of E-waste to
Asia is not limited to China. Indeed, it may well be that as China
begins to enforce its laws, more and more may be flowing to
countries with even less infrastructure and government ability to
protect its citizens from the environmental and occupational
impacts than China possesses. If anything, the first look at India
and Pakistan reveals the conditions to be even worse than those
found in China. For example, in Pakistan, circuit boards are
de-soldered with blow-torches with no ventilation fans and acid
operations take place indoors with less ventilation. In India, open
burning of circuit boards in the middle of New Delhi neighborhoods
is routine as is the use of child labor to accomplish these
tasks.
Imported computers piled high at one of the warehouse yards
in Sher Shah. © SCOPE
disposal in Pakistan. The warehouses work as open markets from
where buyers procure items either for re-use applications or for
scrap processing. It is stated that only 2% out of this whole bulk
can be re-used with slight repair, while the rest is used for
extraction of metals and plastics.
Products extracted from the computers include: Copper, gold,
platinum, plastics, lead, and glass. No special equipment or
protective clothing of any kind is used. All the work in done by
the bare hand. The main parts of the computers are separated, which
include monitors, key boards, mother boards, casing, processors,
floppy drives, CD drives and circuit boards.
E-Waste Recycling in Karachi, Pakistan
Sher Shah in Karachi is one of the principle markets for second hand and scrap materials in Pakistan where all sorts of electronic, electrical, spare parts, computers and smuggled goods arrive into by sea and land for sale or further distribution to other cities in Pakistan. Sher Shah serves as an open informal market, without state controls of any kind. Some of the primary warehouses for scrap computers in Sher Shah include H-Akbar, Quality, and Al-Faisal.
Countries from which the computer waste/scrap comes include; Australia, Japan, England, the United States, Kuwait, Saudi Arabia, Singapore, and Dubai in the United Arab Emirates
Scavengers picking through E-waste dump near Sher Shah, in Karachi. © SCOPE
Monitors
The copper yoke coils found around the picture tube end are the main item dealers look for and which are later smelted for copper alone. The glass and plastic housing are simply dumped and thereafter scavengers might pick their share. The plastic casing of the monitor is either burned openly or is sold at a price of PKR 10 per kilo.
Exporting Harm
23
CD and Floppy Drives
If drives are repairable or usable they are sold in the market;
if not they are broken into pieces with circuits and other parts
separated accordingly.
Circuit Boards, including Mother boards, Cards, Chips and Processors
The methods by which these metals are extracted are very harmful to the workforce due to the fumes emitted during their burning and melting. The circuit boards are first heated by blow-torch and then the valuable chips are removed for further sale or precious metal extraction. Flame is directly applied to the board to remove the remaining solder which is sold at the rate of Rs. 120 per kg.
Worker de-soldering circuit boards with a Bunsen burner in Sher Shah. © SCOPE
from one another. A chemical powder is then applied to further segregate the copper and gold. Platinum can also be removed but this is not done frequently. Then the "goldsmiths" reduce the gold further by melting it into a small bead.
Interviews reveal that the workers and the general public are
completely unaware of the hazards of the materials that are being
processed and the toxins they contain. There is no proper
regulatory authority to oversee or control the pollution nor the
occupational exposures to the toxins in the waste. Because of the
general poverty people are forced to work in these hazardous
conditions. Some say that they don't like the putrid smell, but now
claim they've become accustomed to it.
The material removed from the boards that is suspected of
containing gold is taken to another operation known as "Adda" (in
local language). It is a very primative smelting
operation where workers sit before a small fire-pit fueled by
wood and coal and where air is forced by fans and pipes into the
fire to increase the heat. Here the material is melted to form a
ball which in the local language is called a "sikka". After this
melt, the ball of metal is then placed into acid baths. The effect
of the acid segregates the metals
"Goldsmith" at the "adda" melting down gold bead extracted
after acid stripping process. © SCOPE
Worker using propane torch to de-solder circuit boards.
© SCOPE
Exporting Harm
24
E-Waste in New Delhi, India
In New Delhi the E-waste trade is a thriving business. Areas visited in Delhi included Mandoli, Sader Bazar, Kanti Nagar Extension, Old Sealampur and Turkmangate. Indian E-waste dealers make bids on sea-going containers at the inland depot situated at Okhala. The material is taken out, sorted and distributed between various recyclers according to areas of specialization.
Mr. Chander Mohan, Director of PRCM Metal Limited described the
trade. He obtains scraps from abroad as well as domestically. He
revealed that the Gulf countries and in particular the city of
Dubai serve as centers where scrap and wastes of all kinds from
America, Europe, and West Asian countries are collected and
re-exported. Major buyers from Dubai include China, Pakistan and
India. Mr. Mohan also disclosed that Dubai-based exporters are well
aware of the Indian domestic scrap market and due to this they keep
the price of any scrap at par with the Indian market price.
Women plucking components from circuit boards with pliers and
wire cutters in New Delhi. © Toxics Link India
After some pin straightening, some of the IC chips and
components are sold for re-use. The items that are not worthy of
re-use go directly to the outdoor fires to reduce them to metals.
Following the chip extraction and burning, the boards themselves
are burned in an open pit to retrieve the rest of the solder and
copper. After burning, the ashes are floated in water to remove
lighter ash.
Another process involves utilizing nitric acid on the circuit boards to try to remove gold and platinum. Both methods, open burning and acid baths, are fraught with occupational health risks as well as risks to the people living in the surrounding community. Investigators from Toxics Link India became dizzy within just an hour of breathing the heavy air pollution.
Burning of circuit boards for solder and copper in Delhi.
© Toxics Link India
The circuit board recycling process involves either open burning of the circuit boards or using acid stripping. Both processes first involve removal of the chips, condensers and capacitors from the boards. Very often child labor is employed to separate the parts from the circuit boards utilizing wire cutters and pliers.
Young boy separating parts from circuit boards, Delhi. © Toxics Link India
Exporting Harm
25
Environmental and Occupational Impacts in Asia
Exporting Harm
26
Legal Implications of
Export
Is E-Waste A Hazardous Waste?
There is no question that much of E-waste is a hazardous waste from a scientific/toxicological standpoint. From a legal standpoint, however, the issue has become murky and is dependent on how serious a government intends to deal with the hazards. In the following sections we will observe how various governments have regulated E-waste and additionally, we will look at the international common denominator _ the Basel Convention.
With the exception of Canada and the United States, governments around the world consider E-waste components hazardous wastes and thus tightly control their disposal and export. For most of the industrialized countries, this means banning the export to non-OECD countries and requiring a form of notification and consent to all others. Even those that have not yet implemented the Basel Ban Amendment, they are expected to abide by it prior to its legal entry into force. Virtually all governments, except the U.S. require at least "prior informed consent" for toxic E-waste exports.
It is ironic that a landmark toxicity indicator _ the Toxic
Characteristic Leachate Procedure Test (TCLP) developed by the U.S.
is, nevertheless being ignored by it, through various legal
exemptions (See following Section on the US Law). These exemptions
are not based on science but rather on politics and economics.
Import/Export Controls on Some E-Wastes due to their Hazardous
Designation by Various Countries and the Basel Convention
* Circuit boards are considered hazardous by virtue of the fact
that they contain lead, mercury, nickel-cadmium batteries, etc. If
they did not contain these materials then they might not be
considered hazardous.
**Plastics containing BFRs and PVC are listed here to highlight the fact that most of the world is ignoring this serious issue. Under the Basel Convention they could be considered hazardous particularly if they are converted to dioxins and furans during the recycling or disposal process or contain brominated or chlorinated dioxins and furans as contaminants. But far too little study has been done on the downstream impacts of these "dirty" plastics.
***The Basel Convention contains some vague language with
respect to whether whole computer waste is hazardous but for those
countries such as Australia that have carefully considered the
Basel definitions, the conclusion is rather certain that these
wastes are to be controlled as hazardous waste, unless they have
been stripped of all hazardous materials such as lead, mercury,
cadmium,etc.
18.5 mg/L for lead.46 Thus monitors fail the TCLP.
Circuit boards are far higher in leachable lead content. According
to a study by the Australian government, TCLP levels of lead in
circuit boards were found to range from 142 to 1,325
mg/L.47
On this page is a table showing how some countries and the Basel Convention look at computer wastes and the need for import/export controls on them based on their hazardousness.
The TCLP is meant to replicate long-term conditions in a landfill which allow heavy metals or other toxic chemicals to leach out. The regulatory level for lead in the U.S. is a TCLP of 5.0 mg/L. TCLP levels for monitors due to lead concentrations in the glass test out to be on average about
Exporting Harm
27
material ends up being dumped as non-recyclables or is released as residues, or emissions to air.
The deregulation of hazardous wastes for recycling is particularly troubling because RCRA controls exports of hazardous wastes. Thus, by exempting E-wastes from export regulations, the U.S. subjects the rest of the world to its policy of ignoring the inherent risks in a material simply because somebody claims on a bill of lading that the material will be recycled. While in the past, RCRA never actually banned such exports, it did, however, require a regime of "prior informed consent" so that recipient countries would have to at least agree to importing the wastes prior to receiving them. Furthermore, the United States helped push the OECD into rescinding an earlier OECD Council Decision which bound the United States to "prior informed consent" controls.
By exempting E-wastes from export regulations, the United States subjects the rest of the world to its policy of ignoring the inherent risks in a material simply because somebody claims on a bill of lading that the material will be recycled.
It has been demonstrated too often in the history of waste trade schemes that waste traders can easily claim a recycling destination for any waste. Once the RCRA loophole is proclaimed, it is impossible for the EPA to have any authority to determine whether the exports are truly bound for recycling, whether the recycling is environmentally sound, or whether the wastes are simply being dumped abroad. By providing this gaping recycling loophole the EPA no longer can enforce any controls over exports of hazardous wastes and its eventual disposal. This is a very dangerous policy not only for foreigners subjected to the hazards, but it could also come back to haunt the generators and exporters in the form of liability and compensation claims.
The Australian government, in a rare rebuke, said this about the U.S. recycling loophole:
"This distinction does not make it possible to ensure that exports are truly for legitimate recycling as opposed to "sham" recycling or final disposal…. In general, the US EPA position is based on assumptions of environmentally sound recovery that are appropriate at a domestic level, but which do not accommodate the requirements of the Basel Convention, that exports to other countries be managed in an environmentally sound manner." 52
"The current situation is that the U.S. is exporting electronics and it is not being regulated, and we don't intend to regulate it…. Our policy is that none of it should be hazardous waste; we want it recycled."
— Bob Tonetti, US Environmental Protection Agency48
If the United States were to finally ratify the Basel Convention and the Basel Ban Amendment then of course they would be obliged, as are the 15 member states of the European Union, to ban the export of hazardous E-wastes to China. The U.S. would also have to seriously revise its laws to remove gaping loopholes and exemptions allowed for recyclable wastes. The United States is the only developed country in the world that has not ratified the Basel Convention, even 13 years after its adoption.
In the U.S., not only is it legal to export hazardous E-waste, but in fact, the Resource Conservation and Recovery Act (RCRA)49 has been amended and contorted over time to actually encourage its export by exempting it from export controls of any kind.
RCRA originally controlled more hazardous waste than it currently does. Over the years, RCRA has exempted more and more toxic wastes simply because they are claimed to be destined for recycling operations. The concept of pretending a material is not hazardous simply because it is being recycled is an unscientific, dangerous policy and in fact, is a uniquely North American one. Most countries have accepted and adopted the definitions and policies of the Basel Convention, which makes no distinction between wastes bound for recycling and final disposal in its hazardous waste definitions and controls.50
The concept of pretending a material is not hazardous simply because it is being recycled is an unscientific, dangerous policy and in fact, is a uniquely North American one.
The U.S. has adopted this misguided policy despite the fact that
historically hazardous waste recycling is responsible for about 11%
of US superfund sites and represents some of the most polluting
enterprises ever known.51 The policy was adopted despite
the fact that all recycling involves some final disposal of
residues. Indeed, what we have discovered in Asia indicates that
very much of the imported
Exporting Harm
28
This mentality perpetuated now by the United States is an affront to the principle of environmental justice, which ironically was pioneered in the United States and championed by the EPA domestically.55 The principle states that no people because of their race or economic status should bear a disproportionate burden of environmental risks. While the United States talks a good talk about the principle of environmental justice at home for their own population, they work actively on the global stage in direct opposition to it.
Indeed, facilitating the rapid departure of toxic E-waste from U.S. soil seems to be a priority for the EPA. According to Bob Tonetti, of the EPA Office of Solid Waste:
"I feel strongly about preserving the export markets for electronics because otherwise we would not be collecting electronics in the U.S. Do you think we're going to build new smelters in the U.S.? No, I don't think so."56
In other words, as we're closing down heavy metal emitting smelters across the U.S. in order to protect our own people and environment, we are more than ready to export to smelters and other dangerous technologies abroad.
Exemptions, Exemptions, Exemptions
It is abundantly clear under RCRA that without the recycling loopholes and exemptions, circuit boards and CRTs would be considered hazardous waste as these materials exceed the threshold for lead in the EPA's Toxic Characteristic Leaching Procedure (TCLP) test. This means that the materials are expected to leach lead over time when deposited on land or in a landfill. Under RCRA these circuit boards and CRTs have an EPA hazardous waste number of D008 under 40 CFR 261.24, and thus meet the determination of hazardous waste under 40 CFR 261.3.
But rather than controlling these toxic materials as intended under RCRA, numerous exemptions are now available to avoid regulation. These exemptions make no scientific sense but are a result of an industrial lobby, eager to remove EPA controls and avoid manufacturer responsibility for creating hazardous materials.
Most E-waste is essentially exempt from federal regulation, one way or another, unless the waste generator is a large volume generator who has spent the money to test the hazardous material, notifies the EPA, and admits that the waste is going to be disposed of rather than recycled.
RCRA exemptions for hazardous electronic waste include:
The Basel Convention calls for all countries of the world to become self-sufficient in waste management and to minimize all transboundary movements of hazardous wastes. The Basel Ban Amendment forbids the export of hazardous wastes from Organization of Economic Cooperation and Development (OECD) to non-OECD countries.
However, rather than working to fulfill the global obligation of national self-sufficiency in waste management set forth in the Basel Convention, the U.S. is actually investing time and money in developing a program to establish minimum criteria for environmentally sound management (ESM) for countries to follow. The U.S. then hopes to eventually promote exports to developing countries who meet this minimum criteria. This work is being heavily promoted by the U.S. and is being formulated within the OECD's framework.53 The goal of all of this is to be able to continue exporting wastes to developing countries in Asia and elsewhere via the password of "recycling" and with an ESM seal of approval.
Because the series of OECD meetings on ESM in Recycling Operations have pointedly been designed and funded by countries wishing to undermine the Basel Ban, non-governmental organizations, Clean Production Action, Basel Action Network, and Greenpeace International, have all boycotted and denounced the meetings.54
Even if one did not believe in the principle that wastes should be handled by those responsible for creating them; and even if one somehow believed, against all evidence, that it would be possible in developing countries to operate state-of-the-art hazardous waste recycling facilities; even if one further believed that the infrastructure and resources in developing countries would be present to ensure optimal operation of such recycling technologies (when we can't even manage our own smelters in this country without grotesque levels of pollution) - the fact would remain that the waste exporting country would have transferred the inevitable by-products of hazardous waste recycling to the recipient country. These would include: harmful residues, emissions, and mountains of non-recyclable trash to be dealt with. Why should Asia be the recipient of all of the world's E-waste simply because they are relatively poor?
While the United States talks a good talk about the principle of Environmental Justice at home for their own population, they work actively on the global stage in direct opposition to it.
Exporting Harm
29
· Household E-waste Exemption -- No matter how toxic the waste, if it is generated by any household in the U.S., it is exempt from federal regulations.57 This is why many toxic electronics are ending up in landfills. Although there are no figures available for the amount of household E-waste generated on a national scale, local jurisdictions have produced some interesting data. (see "The Story of Seattle, King County" section for some numbers).
· Conditionally Exempt Small Quantity Generators -- Small businesses are exempt as long as certain conditions are met: they must generate less than 220 pounds/month, or about 7 - 8 computers/month of hazardous waste; and that the waste is placed in sufficient containers, etc. This is a loophole created for small businesses.58
· Large volume generators -- Corporations and institutions are not exempt from regulation completely, like households and small businesses, however, their E- waste falls out of RCRA through other exemptions:
• Processed Scrap Metal Exemption -- Circuit boards with lead and mercury are exempt from the definition of solid waste, and therefore from designation as a hazardous waste because of the processed scrap metal exemption for recycled materials.59 This exemption applies as long as they have "minimal quantities" of mercury and nickel-cadmium or lithium batteries. "Minimal quantities" is not defined by the EPA but left up to the waste generator to determine, should they desire. Processed scrap metal must also be stored in "sufficient containers" (cardboard boxes are acceptable) and must be recycled (including export) in order to qualify as exempt.
• Precious Metal Exemption -- If a company
generating shredded circuit boards admits to having more than the
undefined "minimal quantities" of mercury and batteries, their
toxic material can still avoid regulation under the
"precious metal exemption" simply because it has
economic value. This conditional exemption is based on the
presumption that because they have precious metals in them, "these
materials will be handled protectively as valuable
commodities".60 Thus despite the presence of lead, tin,
brominated flame retardants, more than "minimal quantities" of
mercury and
cadmium or lithium batteries, they are still exempt from
regulation.
• Computer Monitors from large volume generators are not handled as hazardous waste if they are going for recycling, even though they have failed the EPA's test for lead toxicity. Because of poor federal regulation of monitors, some states such as Massachusetts and California have gone beyond RCRA regulations and have banned them from their landfills, even if they originate from households and small quantity generators.
• Plastics with toxic brominated flame retardants are going to landfills and incinerators around the U.S. as they are not considered hazardous under RCRA.
The EPA is in the process of proposing a "Special Rule" for CRTs that would control CRTs if they are broken, but would continue to allow all households and small quantity generators to send toxic monitors and circuit boards to landfills, and continue to lift controls on exports as long as recycling destinations are claimed.
In sum, the widespread exemptions for electronic waste have been specifically designed to remove regulatory barriers not only from domestic recycling, but also from exporting these hazardous wastes offshore. While other countries are accurately identifying the lead, mercury, cadmium, and brominated flame retardants in some electronic waste and treating them accordingly as hazardous waste, the United States is facilitating the departure of these toxic wastes to developing countries where people and environments are being impacted at alarming rates.
Chinese Law
China was one of the first global proponents for an international
ban on the export of toxic waste from developed to developing
countries. It is significant that the 1994 proposal which became
the basis for the decision to ban such waste trade in the Basel
Convention on the Transboundary Movements of Hazardous Wastes and
Th>
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concerned under the State Council, shall be ordered to transport back and return the solid wastes and may be imposed a fine exceeding 100,000 yuan and not exceeding 1,000,000 yuan concurrently by the Customs. Anyone who evades Customs supervision and control and constitutes a crime of smuggling shall be investigated for criminal responsibility according to the law."62
The law contains annexes of wastes that are allowed or prohibited as raw materials imports. As a result, many hazardous wastes are forbidden from being imported.
Still it surprised many, that in February 2000, China made public SEPA Document No. 19/2000 of January 24, 2000. This document entitled, "Notification on Import of the Seventh Category of Wastes," announced the following new law: "From February 1, 2000, the seventh category of wastes
China was one of the first global proponents for an international ban on the export of toxic waste from developed to developing countries.
In 1996, China passed the Law on the Prevention and Control of Solid Waste Pollution to the Environment which, among other things, (a) prohibits the import of solid wastes which are unusable as raw materials, and (b) strictly regulates the imports of solid wastes that can be used as raw materials.61
Indeed the law stipulates, "Anyone who, in violation of the provisions of this Law, dumps, piles, or disposes of solid wastes moving into the territory from outside the territory of China, or imports solid wastes for use as raw materials without obtaining approval from the competent department
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approved by the State Environmental Protection Administration for import shall not include the following:
• computers, monitors, and CRTs
• copiers
• microwave ovens
• air conditioners
• video cameras
• electric cooking devices, rice cookers
• telephones (except for pay-phones)
• video games (except for processing for re-export)
• televisions and picture tubes
• refrigerators.
Amendment (as they would not be OECD exporters), this move
nevertheless demonstrates conclusively China's support for the
Basel Convention and its overarching goal of national
self-sufficiency in waste management.
The Basel Convention and the Basel Ban Amendment
The Basel Convention on the Control of the Trans-boundary Movement of Hazardous Wastes and Their Disposal was adopted in 1989 and entered into force in 1992. It was created to prevent the economically motivated dumping of hazardous wastes from rich to poorer countries. There are now, as of this printing, 149 countries that have ratified the Convention and are thus "Parties" to it.
In its original version, the Convention called for national self-sufficiency in hazardous waste management, and for the overall minimization of hazardous waste generation and transboundary movements of such wastes.
In its original version, the Convention called for national self-sufficiency in hazardous waste management,and the minimization of hazardous waste generation and transboundary movements of such wastes.
If wastes are to be moved under the Basel Convention--for example if a country lacks the adequate technical capacity to deal with a waste domestically - the exporting country must not allow the export "if it has reason to believe that the wastes in question will not be managed in an environmentally sound manner (ESM)."65 The Convention defines "environmentally sound management" as "taking all practicable steps to ensure that hazardous wastes or other wastes are managed in a manner which will protect human health and the environment against the adverse effects which may result from such wastes."66
The Convention also requires that such export must utilize a paperwork authorization regime known as "prior informed
From April 1, 2000, the Customs Administration will not allow the entry of the above mentioned abandoned electrical appliances."
From the results of our mission to China, and the common knowledge in the recycling community in developed countries of the OECD group, this law appears to be poorly enforced. The reasons for this are as yet unclear. It is not known whether this widespread flouting of the national law is due to a lack of enforcement will or infrastructure. Likely it has to do with both _ a lack of will on the part of local officials and a lack of infrastructure on the part of the central government.
In January of 2002, representatives of the Basel Action Network (BAN) raised the issue of E-waste exports to China and our recent discoveries with Mr. Zhong Bin, Program Officer of SEPA and delegate to the Basel Convention's most recent meetings of their Legal and Technical Working Groups. Mr. Zhong Bin expressed gratitude for our information and further expressed real concern. He reiterated that whole computers, CRTs, monitors, printers, etc. were strictly forbidden from entry into China.63
He reiterated that whole computers, CRTs, monitors, printers, etc. were strictly forbidden from entry into China.
According to Mr. Ma Hongchang of the Solid Waste Management Division of SEPA in Beijing, a possible revision and further elaboration of the existing rules will be forthcoming this year.64
Finally, it must be noted that on 1 May 2001, China ratified the Basel Ban Amendment which effectively will forbid the export of Basel hazardous wastes from OECD, EU, and Liechtenstein to all non-OECD countries including China. While there is no legal obligation placed on China from this
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Among developing countries that are the subject of this report, it must be noted that China, an ardent sponsor and supporter of the Basel Ban, has ratified it. The Indian Supreme Court has likewise reflected the Basel Ban in their directive of May 1997, still in force, prohibiting the import of hazardous wastes into India. Pakistan, as a Basel Party will respect the decision even prior to its strict entry into legal force.
Basel Waste and Hazardous Waste Definitions
The Basel Convention defines waste by disposal destination or recovery processes. These various processes are listed in Annex IV of the Convention. For example, virtually any material that will be recycled or processed in order to reclaim a metal, or to reclaim an organic or inorganic substance for further use, is deemed a waste. Electronic components that are re-used without any further processing are likely to not be defined as a waste.
The Basel Convention does not cover all wastes but rather is meant to control "hazardous wastes" as well as "wastes collected from households" and "residues arising from the incineration of household waste".72
In 1994, to better clarify what wastes are controlled under the Convention, the Basel Parties established two lists of wastes that correspond to common waste streams: List A, found in Annex VIII is presumed to be hazardous and thus covered by the Basel Convention; and List B, found in Annex IX, is presumed to be non-hazard