Pipes Output http://pipes.yahoo.com/pipes/pipe.info?_id=UJowL_kK3RGxzcHXjUnRlg Thu, 01 Oct 2015 11:21:56 +0000 http://pipes.yahoo.com/pipes/ http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/C8iFgWZStiY/the-ftc-as-the-federal-governments-data-security-watch-dog.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401b8d0fddc86970c Thu, 09 Apr 2015 17:28:00 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/UiaFlPpeOBE/top-investment-regulators-reaffirm-focus-on-data-security.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401b7c7743940970b Tue, 07 Apr 2015 16:40:44 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/h2ioukxWW5c/5-reasons-an-it-asset-should-be-retired-even-if-it-still-has-book-value.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401bb08036806970d Wed, 11 Mar 2015 12:26:59 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/DLX0JZG44eA/what-firms-see-as-important-it-asset-disposition-issues-in-2015-1.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401b7c7236b3a970b Fri, 19 Dec 2014 05:15:12 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/eotETCa_wM0/how-to-mitigate-risk-or-increase-the-value-of-it-assets-what-people-think.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401b8d0a1ede6970c Fri, 05 Dec 2014 04:50:10 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/mu6OQwn1gG8/whats-it-worth-during-disposal.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401b7c7040b20970b Mon, 10 Nov 2014 20:06:36 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/ba7ozdjnuY0/report-from-the-sept-22-23-epa-sustainable-materials-management-forum.html By Neil Peters-Michaud, Cascade Asset Management ---------------------- Earlier this week (September 23-24, 2014), I was honored to be invited to participate in EPA’s Electronics Reuse and Recycling Forum in the Washington, DC area.  It was reported this was the first mutli-stakeholder gathering to discuss issues and opportunities with EPA’s Office of Solid Waste and Emergency Response in relation to Sustainable Materials Management (SMM) in the electronics reuse and recycling industry in over nine years.  After two full days of facilitated proceedings, a set of priorities was developed for the EPA and other members of this industry which address existing and impending challenges in this industry. The discussion first focused on issues surrounding cathode ray tube (CRT) glass management.  In the past eighteen months, there have been numerous instances of abandoned piles of leaded CRT glass found at defunct electronic recycling businesses in Arizona, Utah, Ohio, Maryland and Pennsylvania.  In fact, e-Scrap News estimated more than 25,500 tons (51 million pounds) of this CRT glass was discovered unprocessed over the previous 2 years.  Much of the responsibility for cleaning up this leaded glass (which does cost money to properly recycle or treat) is falling on the property owners of the abandoned sites, the original generators who sent equipment to the sites, acquiring firms who needed to assume these liabilities, or taxpayers.  At the EPA meeting, participants warned of a continuing problem with CRT processing as more recyclers are speculating about end markets for the product by charging fees to consumers and generators of this equipment (coming from TVs and monitors often collected through household recycling programs) and hoping the eventual cost to recycle these products decreases as new markets come on line.  Many people noted this is a ticking time bomb. Based on feedback from the meeting, it was recommended EPA and the industry take specific initiatives to combat this environmental disposal challenge.  There was general agreement that the EPA and corresponding state agencies need to be more aggressive in inspections and enforcement actions to prevent, or more immediately respond to, improper speculation, storage and handling of CRT waste piles – there was even an expectation set that at least one enforcement action should be completed before the end of the year, since the industry knows more CRT stockpiles are currently mismanaged.  There was also a discussion about reviewing alternative CRT recycling options.  It was reported the demand to process CRTs for glass-to-glass recycling at Videocon may only be available for another four years until that market evaporates.  Videocon is where many processors (including Cascade) send leaded funnel and non-leaded panel glass from CRTs to be melted down into glass product sold back in into the glass market as a clean raw material used in new CRTs.  Other options discussed include sequestering CRT glass until a future economically and technologically feasible recycling option is developed, treating CRT glass and applying it as alternative daily cover onto landfills, sending leaded and non-leaded glass into ceramic tile applications, using the glass in concrete, and sending tubes to secondary copper and lead smelters.  All options have some risks and disadvantages, which makes this a difficult choice over the next decade as the industry works its way through this legacy CRT waste. Beyond the CRT issue, the group also focused on the need to better understand environmental, health and safety risks associated with the processing of mercury lamps (in many LCD TVs, monitors and laptops) and batteries.  There is a clear consensus  these materials represent the fastest growing challenge in the e-waste stream, yet many processors are not aware of the handling and disposal hazards from these products.  Also, there is no clear set of regulations related to the collection, treatment, storage and disposal of these products.  The group recommended EPA issue a letter of interpretation to help the industry understand how existing laws (such as RCRA and the Universal Waste Rule) apply to these mercury lamps and batteries so that that processors are better informed about compliance requirements and regulators know how to enforce existing laws related to these materials. Besides the detailed discussions on the final recycling of electronics, there was a healthy discussion about opportunities to expand and encourage reuse and repair programs to extend the useful life of electronics.  Some current and potential barriers to repair and reuse were identified.  For example, there are several state legislative initiatives to require cell phone manufacturers and carriers to enable the adoption of a “kill switch” on their devices (with the belief that this will discourage theft of these devices).  This legislation would make it impossible for refurbishers (like Cascade) to be able to repurpose and resell these phones.  This would have dramatic financial and environmental impacts.  The smart phone reuse market is reported to be at least $5 - $7 billion annually, and the opportunity to extend the life of these phones generates tremendous environmental benefits.  Another ongoing challenge to reuse is FCC and Congressional action focused on copyright law which would restrict users and refurbishers from unlocking cell phones or altering the firmware of hardware.  This action can render reuse and repurposing of these devices impossible.  Participants recognized the EPA must take a leadership role to convene other federal agencies to demonstrate that their good intentions to protect supposed intellectual property rights might be causing millions of IT devices to be rendered unusable and destined for the scrap heap.  Other good ideas that emerged from the discussions included a plan to convene IT product designers and repair/demanufacturing firms to offer feedback that encourages more responsible electronics manufacturing that should help to avoid reuse and disposal problems.  In addition, participants discussed the need to review the certification programs to ensure they are sound and that they offer a real distinction between the good and bad actors. The work from this forum will continue.  Participants pledged to join in follow-up activities and the EPA said it will work toward defining its own plans of action based on the discussion from the meeting.  I am hopeful there will be effective and immediate responses from this event.  Some of the challenges require bold steps and we all need to step up with the EPA to enable these positive actions to take hold. Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401b7c6e7d61e970b Fri, 26 Sep 2014 04:51:19 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/FL44VepLeN8/hipaa-update-omnibus-rule-compliance-enforcement-updates-risk-assessment-tool.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401b8d06258d6970c Wed, 03 Sep 2014 13:18:35 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/pwI2dSftAts/sec-turns-focus-to-data-security.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401a511f65a1d970c Thu, 14 Aug 2014 12:28:47 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/Y3chVG0pg2A/milwaukee-cio-forum-highlights.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401a73d88651a970d Wed, 05 Mar 2014 20:08:21 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/it_asset_retirement_value/~3/tmkSGi58oHM/encryption-and-lojack-protect-data-in-use-but-not-in-disposal.html Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a48834019b027efb6c970d Tue, 10 Dec 2013 03:28:28 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/hdLnoLBWJlM/hr-2791-responsible-electronics-recycling-legislation-reintroduced.html With bi-partisan support, the Responsible Electronics Recycling Act (RERA) was just reintroduced into Congress as HR-2791.  This bill has garnered wide support from the business community and environmentalists.  HP, Dell, Apple, Samsung and Best Buy have publicly endorsed this program which provides greater assurance their products are responsibly recycled.  The Electronics TakeBack Coalition, which represents a large number of non-profit consumer and environmental advocacy groups, call this the “most important step our federal government can take to solve the e-waste problem.”   The Coalition for American Electronics Recycling, which represents more than 100 large and small independent recyclers in the United States, also sees this bill as a boost to the economy that can generate more than 42,000 new jobs. It’s about time the legislation has been reintroduced.  In the two previous Congressional sessions RERA was put on the floor by Representative Gene Green (D-TX), the bill received good interest from fellow members (there were 22 co-sponsors in the House including 13 Republicans in 2012). Unfortunately, the bill never received a hearing.  The lack of movement on this bill in Congress in the past was primarily due to other priority issues (debt ceiling, sequester, etc.) getting in the way.  I’ve been heavily involved in the evolution of this bill over the past two years, working as a member of the CAER Steering Committee and providing comments to the individuals drafting this bill.  I’ve also spoken directly with my colleagues in ITAD and recycling businesses to learn their concerns about the impact of this proposed legislation.  Some of those concerns have led to changes in the bill to make it more effective and fair.  For example, licensing requirements are much more streamlined and the “amber” control provision for the export of circuit boards was dropped to keep this law consistent withcurrent OECD regulations.  There were other concerns expressed about this bill that I found to just be misinterpretations.  This bill still allows for the export of tested, working equipment.  It just requires firms to validate the equipment is working and intended for reuse.  This is something any R2 or e-Stewards firm must demonstrate to their auditors right now.  The bill also does not place unfair burdens on small businesses and favor large firms.  First of all, it does not add any regulations to firms engaged in domestic collection and recycling services, which is what most small firms and non-profits are limited to.  Instead, it places some basic requirements on what can be exported to non-OECD countries, and how these materials must be prepared and reported prior to export.  The bill fully supports responsible reuse and responsible export.  That being said, anyone engaged in export should be expected to have some knowledge of international shipping manifests and export rules.  Again, R2 and e-Stewards firms should be ready to comply with this law without much trouble.  The law is meant to stop the bad actors which are not properly following certification programs and tell consumers their electronics are being responsibly recycled while they cart this hazardous e-waste into the developing world. Now that RERA has been reintroduced, it’s time to get the bill debated within Congress and across the country.  Then, the House must bring it to a vote.  This is its third run in Congress.  Maybe the third time is the charm. Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a48834019104616bd5970c Wed, 24 Jul 2013 14:04:39 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/YSQFW2JYrhk/limiting-exports-is-not-racist.html I remember a time (not so long ago) when the owner of another e-scrap processor headquartered in the U.S. said, "the Chinese are happy to take any job they can get.  By exporting our scrap to them for processing, they can make more money processing this stuff then they'd ever dream compared to slaving in their fields."  The conversation occurred while we drove in his fully equipped Audi. He thought his export of mixed, hazardous, electronic waste was a good thing for Chinese workers.  He was completely convinced. I think differently.  I haven't been to China to see for myself the impact of e-waste exports into this country, but I've seen the videos and have talked to others who've been there.  They report that in most cases, the conditions for extracting recoverable materials from the West's e-scrap are poisoning the workers. I have traveled to Africa on five different occasions over the past five years and have witnessed their capacity for processing e-scrap.  There are no precious metal smelters in East Africa; no lead smelters that will accept CRT glass; no mercury retort ovens.  The ferrous metal processors operate rudimentary arc furnaces to melt steel scrap into rebar and razor wire, with minimal air emission controls.  There was an impressive interest and ingenuityfrom individuals to repair, refurbish and extend the life of computer equipment, but there was essentially no industry to actually convert disassembled electronic scrap into recoverable materials. On one visit, I was hopeful that I found a secondary lead smelter which would accept CRT glass for recycling.  I located a firm advertising itself on the Web which claimed to operate such a facility in Addis Ababa, Ethiopia.  With the help of a translator, we called their phone number, but couldn't get through.  We had an address, so we tried to find it.  After driving around a residential neighborhood and asking local residents, we discovered the place was a hoax.  No such facility existed.  It's good to check out these claims with your own eyes. So if our company chooses to not send electronic waste - that electronic "stuff" that can't be reused or isn't shipped out as a clean metal or plastic commodity - to a developing country that is still trying to create its own manufacturing basis, does that make us racist?  Some people think so, because they claim we are denying them their right to make money off this scrap while we drive around in our Audi's. I think it's time we all recognize that there is a difference between the developing and the developed world, and we must work together to bridge this divide.  We do this not by exporting the waste that Western countries don't care to process themselves to low-labor cost countries, but by capacity building in developing countries to help them build industries to safely and effectively process their own waste. When our company chooses to not export unprocessed, non-working, e-waste to developing countries, that doesn't mean we are racist or we deny the opportunity to let people earn a livelihood.  It means we're taking responsibility for our waste and choosing to internalize the cost of this activity rather than pass it on to other parties who don't necessarily have the capacity to manage these materials properly to final reclamation. When I spoke with the manager of the ferrous recycling operation in Ethiopia, she told me that she wants clean ferrous scrap, not the mixed amalgam of metals, plastics, and toxins from electronic scrap.  We do export materials around the world - clean, processed metals, glass and plastics.  These are raw material commodities that can be used in the manufacture of new products that have been properly purged of the poisons that pollute in the conversion process.  We support export that creates sustainable manufacturing industries around the world.  Do we really believe that the dream of someone in a developing world is to process our toxic e-scrap?  I think they would prefer to dream of driving a well equipped Audi. Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a48834017ee9f7caff970d Thu, 04 Apr 2013 03:35:25 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/T4FQsYXq8-A/initial-thoughts-on-the-250-page-international-trade-commission-report-on-used-electronic-product-ex.html The United States International Trade Commission released a report on March 8, 2013 titled “Used Electronic Products: An Examination of U.S. Exports.”  (see http://www.usitc.gov/publications/332/pub4379.pdf).  This 250 page report details the process the commission took to collect information from organizations involved in the industry (through surveys, public hearings, facility tours and interviews) and also through a review of Customs records of exports of IT devices, which they term “Used Electronic Products” or “UEPs.” It then presents findings from their research.  This is an important body of work that contributes to the overall discussion about the scale of the electronics recycling industry, its contribution to “clean” and “dirty” exports, and what we should do to improve the industry overall.  That being said, the report is honest about the limitations of its data collection methodology to provide an authoritative set of conclusions about the UED industry and exports.  For example, the report stated, “Relying on survey data presented several  challenges to the Commission’s findings. The results of the Commission’s questionnaire have been aggregated and weighted to provide estimates about a broader population, with results that may be skewed towards nonexporters or responsible exporters  that responded to the questionnaire, as well as to larger firms, since very small firms were not surveyed.” (Page 1-8).   There are many other instances where the report questions its own veracity and acknowledges biases in its methodology.  As a result, readers should be careful about drawing certain conclusions from the report.  Anyone who claims that the report says exports of untested or unprocessed UEDs are not a problem did not read the full report.  The report states, “Informal and unregulated recycling of exported UEPs remains a concern within the industry. No quantitative data on this segment of the industry are available, but some descriptive information is included in this report.” (p. xviii) In general, I believe the industry should carefully consider the findings of report, while concurring with the authors that the report has limitations in its ability to ascertain the true amount of export of untested, non-working and hazardous e-waste to developing countries. The report makes some very important findings: The amount of exports of used electronic products (UEPs) is significant and Congress should take notice.  The report finds that 757,721 tons of UEPs were exported by the US in 2011. (p. 5-2).  That number may even be under-reported. That’s a lot of electronics! There are a large number of firms engaged in this enterprise.  The survey included responses from 2,670 organizations out of a total of 4,701 qualified U.S. firms.  Again, this is clearly a significant U.S. industry.  They did not even include firms with less than 10 employees in this group. The study commented on the Responsible Electronics Recycling Act (RERA) and said, “However, [if RERA were enacted into law] the product mix [of export] would likely change to reflect more tested and refurbished products and fewer end-of-life products [exported]. Conversely, exports of commodity-grade material would likely increase, as more recycling activity would take place in the United States and UEP-derived commodities would be exported to manufacturing centers in non-OECD countries.” (p. 6-8).  This is a great argument in support of RERA. The testimony from business owners captured in this report who oppose outright bans on the export of electronics to developing countries also admit to exporting tested, working equipment abroad.  This activity is actually supported in RERA,  since it does not ban the export of tested, working equipment.   We need to clear up this myth because a law like RERA actually helps protect and encourage this export of tested, working, and clean processed commodities and would be good for their business. The study makes numerous references to the concern from businesses, NGOs and others about the export of electronics to the informal sector in developing countries.  It recognizes that e-waste export concerns are not relegated to a fringe group, but are shared by a wide range of businesses. ITC recognized that the veracity of respondents to the survey may be questioned and that people may not want to report illegal shipments of electronics overseas, so the findings should recognize that bias.  There are many interesting points made throughout the report that warrant discussion and debate.  That’s a good thing.  But we also need to be careful to not claim this report draws conclusions that just aren’t there.  Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a48834017ee93e76a7970d Wed, 13 Mar 2013 00:34:08 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/blDP08fZB2s/building-a-sustainable-economy-in-2030-part-2.html As we look to develop a vision for a sustainable ICT infrastructe in 2030, I believe we should focus on the following: Voluntary standards should establish best practices that are on the cutting edge and would eventually lead to requirements that all most follow (either through regulatory mandates or because the alternatives no longer are attractive).  Voluntary standards should not replace mandatory requirements when these requirements are necessary to create a level playing field and advance socially accepted priorities. Government should support and invest in renewable energy infrastructure development to allow these technologies to work off of a green grid. Government should invest in research to develop new materials that improve American competitiveness in sustainability. Government should focus on education, to create a skilled workforce to enable the development of new ideas in private industry. Government should end subsidies for non-renewable energy sources and mining which degrade our environment and is a disincentive to the development of the sustainable electronics industry. The global economy will play a role in our transition to a sustainable electronics industry.  The healthier, the better for investments in long-term projects like this. Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a48834017ee43f5951970d Thu, 18 Oct 2012 05:14:48 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/qBulha3284w/building-a-sustainable-ict-economy-part-1.html I am honored to be involved in the Sustainable Electronics Forum hosted at the Wingspread Conference Center by the US EPA.  About 30 representatives from industry, government, and academia are grappling with how to define what a sustainable IT economy would look like in 2030.  Here are some of the questions I'm expecting we will consider over the next couple of days: What will be the material composition of products and can we sustainably source these materials through recycling and recovery processes, renewables, biobased materials, or some other new innovation?  Can we continue to innovate and generate new products without depleting non-renewable resources? Electronics require energy to operate.  Can we generate that energy through more sustainable processes, including kinetic, solar, etc.?  How can we improve stored energy issues?  Batteries need to be improved in order to support portable devices.  How can we extend their lives, reduce their toxicity and make them safe to handle and dispose? There will be electronic products we will be using 20 years from now that cannot be predicted.  Smartphones did not exist 10 years ago.  How do we define the future when it’s difficult to predict the basic tools we’ll use? The drive to innovate encourages the rapid development of new technologies and products, which promote rapid obsolescence of legacy products.  If consumers want to always get the latest gadget, the disposal of electronics will continue to accelerate.  How can we innovate in “durables” without making them “disposables”? The world will continue to become more interconnected.  Consumer technology is spreading quickly across the globe.  Emerging markets are adopting technology at a significant pace, and they have a good infrastructure to support it.  How do we account for these trends? People want so much – we want access to information at fast speeds, reliably.  The drive to meet these demands can run counter to environmental goals which require us to set limits.  Do we need to change people’s expectations for electronic products in order to achieve a sustainable electronics industry? We need to understand marketing and consumer psychology. What is it that consumers want and how can we provide attractive products to them that are sustainable? I'm sure many other questions will arise during this process, and I hope a roadmap and action plan to proactively prepare for the future will develop.  I'll let you know how it goes.   Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a48834017c3294864d970b Wed, 17 Oct 2012 05:06:48 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/tG-NN_uY5H4/is-epa-listening-to-processors-about-voluntary-electronics-recycling-standards.html I'm participating in a listening session hosted by US EPA and the GSA to get input on the voluntary electronics recycling standards (e-Stewards and R2). EPA is trying to make sure these standards, and any other standard that might throw itself into the ring, meet a set of minimum environmental requirements to be used by federal government agencies when disposing of electronics assets. The stated purpose of today's listening session is to, "investigate the implementation of current electronics reycling certification programs, including the following: vigorousness of facility and downstream audits; consistency and frequency of audits; auditor training; documentation of exports, internet sales; and, real world outcomes of certification processes." The EPA and GSA are embarking on a two phase study. First, they are conducting research by gathering input from ANAB, certifying bodies, the certification programs, and through listening sessions. Then, they plan to perform witness audits at electronics recycling firms to see for themselves how effective theprograms are. Their goal is to make recommendations, as appropriate, for potential improvement to the certification process. It appears EPA wants to find out, as a potential user of processors, whether the R2 and e-Stewards certifications meet an as yet undefined set of environmental standards. This seems like reasonable due diligence to protect the government (and ultimately us American citizens) from disposing of hazardous e-waste in an irresponsible and illegal manner. A lot is riding on this evaluation. With more than 275 firms certified to the R2 or e-Stewards standard, there are clearly a lot of options for the federal government to recycle according to its current stated selection process. But is that a sufficient guide? I am hopeful this EPA study will recognize the differences between the two standards, differences among certifying bodies auditing to these standards, and differences among processors holding each standard. I suspect EPA will find significant disparities within each of these areas. There were several processors in the listening session who shared their experience with e-Stewards being more rigorous than R2. No one said R2 was more rigorous than e-Stewards. Through this process, I expect EPA will come to witness this difference. But will they finally report this finding and say that e-Stewards sets a higher bar than R2? Would EPA say that R2 is good enough or will it realize that R2 contains loopholes to give pause to federal agencies who might be liable for the malicious acts of a certified processor that could lead to illegal dumping or export of equipment with sensitive federal data? Also, how will EPA treat the variation in auditing processes and the implementation of standards at processors? Within the group of companies certified to each standard, some are definitely better than others. EPA's unconditional endorsement of either or both standards would lead to a race to the bottom for each standard's requirements because there would be no market based incentive to do more (it's not like a company would get more federal work by being more responsible). Many private companies see 3rd party certifications as a minimum threshold for selecting processors for work. Then, they look specifically at the company (which often includes their own on-site audits) to ensure the processor is effectively meeting its own requirements prior to engaging in service. The federal government, through the GSA, should do that as well if it wants to be a leader in environmentally responsible asset disposition. Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a4883401761521c62a970c Thu, 07 Jun 2012 18:49:56 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/6bkhNLkpVUE/is-restricted-trade-in-e-waste-protectionist.html I've heard opponents to the Responsible Electronics Recycling Act claim that is is just another protectionist trade policy that hurts US business.  Regulation can always impact businesses, but the companies that adapt to comply with these new requirements will succeed.  The purpose of government regulation should not be to hurt or help business, it should be to protect the common good of the people who enact it.  Our country has historically restricted the trade of hazardous waste and the export of products/information that pose a threat to national security.   That’s what this bill will do.  E-waste is generally considered a hazardous wastesince TCLP tests demonstrate that most electronics with circuit boards, fluorescent lamps, CRT screens and batteries contain sufficient concentrations of hazardous materials to classify them as a hazardous waste.  In addition, there are documented cases of sensitive and classified information found on recovered media from unprocessed electronic equipment shipped from the US to developing countries.  This represents a real national security risk.  In the past, Commerce has restricted trade of information technology equipment to certain countries who are enemies of America. It’s also important to recognize that in no way does the bill enact a wholesale ban on the trade of electronics or e-waste.   There is a restriction on what can be exported to developing countries, but any electronic product or e-waste can be exported to other OECD countries where it is more likely there is a sound process for managing this waste and protecting our secrets. I believe tested, working electronic products should be freely traded, and this practice is preserved by the bill.  I also believe processed commodities that do not contain “restricted electronic waste” should be freely traded.  A concerned and an informed citizenry must restrict the wholesale export of untested, non-working e-waste to developing countries.  It is just the right thing to do.  Businesses will adapt. Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a488340162fdbba7ba970d Tue, 13 Dec 2011 03:28:44 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/dcMO77qcR8U/can-a-domestic-e-waste-industry-build-capacity-effectively-if-exports-were-banned.html I was surprised when I was again asked by government officials in Washington, DC about whether the American electronics recycling industry can ramp up capacity fast enough to absorb the onslaught of unprocessed electronics that will no longer be allowed to be exported to developing countries if the Responsible Electroncis Recycling Act passes Congress. First of all, the export ban in the proposed legislation goes into effect 2 years after its enactment.  This affords the industry sufficient time to develop plans, make investments, install equipment, hire staff, and essentially grow to meet the expected increase demands from this change.  In addition, industry representatives from the Coalition for American Electronics Recycling report that they all currently have significant excess capacity and can add work shifts (employing more people) and increase processing equipment utilization without additional capital outlays.  Third, the same concern was raised earlier about the industry developing a collection infrastructure to respond to state landfill bans of e-waste.  But this problem (lack of capacity) never materialized because firms were able to quickly set up or grow appropriate resources to meet the new demand.  In California, hundreds of companies registered as Collectors for that state’s e-waste recycling program within two years of its enactment. In the business world, growing capacity to meet increased demand for products or services is a challenge we are more than happy to solve.  Government officials have no reason to be concerned about whether business wants to make investments, create jobs and boost profits by ramping up capacity to meet increased demand for services. Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a488340154378cfaac970c Tue, 29 Nov 2011 03:46:04 +0000 http://feedproxy.google.com/~r/typepad/cascadeam/enviroregulations/~3/Pk_gmlbGdXE/launch-of-website-for-coalition-for-american-electronics-recycling.html A new website for a business group of electronics recyclers was just launched today at www.americanerecycling.org.  The website contains a wealth of information about the proposed Responsible Electronics Recycling Act (HR 2284 / S1270) now in front of Congress.  The Coalition for American Electronics Recycling represents U.S. companies that believe electronics recycling should be performed securely and sustainably, for the benefit of the American economy. It is committed to growing an American industry with the capacity to manage the volume of e-waste generated within our borders, creating good jobs and expanded trade. The Coalition of independent businesses was formed in the summer of 2011 to demonstrate to Congress that businesses do support the passage of the Responsible Electronics Recycling Act.  Cascade Asset Management is one of the companies directly involved in this campaign. Neil Peters-Michaud tag:typepad.com,2003:post-6a00e54ef855a488340162fc4110a8970d Wed, 09 Nov 2011 19:02:07 +0000