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    Toxics in Electronics Redux: Greenpeace Responds

    By Keith R | October 30, 2006

    Topics: Corporate Social Responsibility, Electronic/Electrical Equipment, Environmental Protection, Hazardous Substances, Waste & Recycling | No Comments »

          
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    As I noted here previously on the Temas Blog, a few weeks back Treehugger invited me to guest blog about my reservations concerning Greenpeace’s handling of its report on the testing of laptops for certain substances. My entry drew quite a few comments, including a long, detailed reply reputedly penned by the scientist who did the report for Greenpeace. I responded to his points in the same comments section.

    It’s since been pointed out to me that often people don’t read comment sections, on Treehugger or blogs such as mine, so many may have missed my exchange with Greenpeace on Treehugger’s pages.

    Frankly I was surprised to hear that, since I like to read the comments on interesting blog entries because the comments section is where you can often find additional information, clarifications, expansions, alternative takes on the issue, pointers to other discussions of the subject matter, and yes, debate. Blogs are supposed to be about “the conversation,” right? I find that much of the most interesting conversing actually takes place after an article rather than during it.

    That’s why I make a point of commenting when I think I might have some value added to offer, and can tell the author I think he/she is on the right track or has reached me, made me see things in a new light. It’s also why I not welcome comments here at the Temas Blog — as long as it’s civil and on-topic (and not spam!) — and even offer readers the option of tracking comments by RSS feed or email.

    Anyway, it was suggested that maybe I should reproduce here Greenpeace’s response to my Treehugger piece and my reply to them. So here you have it.

    For Temas Blog readers who already read all this over at Treehugger, I apologize. Skip what follows (unless you wish to comment below and continue the conversation/debate — in which case, by all means, please do!) and scroll down to read instead about coconuts (Smile). For those of you who did not catch this before over at Treehugger, I hope it provides food for thought, and perhaps more importantly, prompts you to offer your own perspectives as comments.

    Respectfully,
    Keith R

    ——————————————

    First the Greenpeace response:

    Hello Keith

    Here is a Greenpeace response to your post about the details of the laptop testing report from Dr. Kevin Brigden, who wrote the report on laptop testing:

    Greenpeace references to ewaste in China and India is because we have visited these recycling yards, where we found evidence of large amounts of ewaste from US, Europe and Japan being recycled in primitive conditions. Testing shows the environmental contamination of recycling yards at:
    http://www.greenpeace.org/raw/content/international/press/reports/
    recyclingelectronicwasteindiachinafull.pdf

    See also:
    http://www.greenpeace.org/international/campaigns/toxics/electronics/
    where-does-e-waste-end-up

    Other NGOs, such as Basel Action Network have documented similar dirty recycling practices in Africa at: http://www.ban.org/BANreports/10-24-05/index.htm

    UNEP has also evidence of e-waste dumping around the world at:
    http://www.grid.unep.ch/product/publication/download/ew_ewaste.en.pdf

    With respect to testing of laptops, yes the sampling was limited – it’s very time-consuming and costly and highly technical. We demonstrated that even from such a limited study it was possible to find toxic chemicals (including those manufacturer had claimed to stop using).

    In the case of HP, although HP claims on its website that it has not used one type of brominated flame retardant – decaBDE – for years, testing of this one model showed this statement to be false.

    No cadmium or mercury was found – yes, but other toxic chemicals where identified.

    Lead was found at 4.5% – 13% – lower than in some electrical solder, but 45-130 times the RoHS limit for lead (RoHs didn’t apply to these models, but is a useful benchmark)

    We analysed for a range of BFRs. No we didn’t find every single chemical we looked for, but we didn’t expect to. This shows that hazardous chemicals can be phased out – as far as we know PBBs are not now incorporated into products (though we wanted to check – you never can be sure that you are given correct info)

    Only traces of TBBPA /PDBEs – we found high levels of bromine at 0.19% to 9.4% (that’s almost one tenth by weight of bromine!) in around a quarter of all the components and materials tested. Bromine levels are indicative of BFR levels, though do not show the actual chemicals.

    Due to the time and cost of the highly technical analysis we were only able to analyse one sample part from each laptop model for the BFRs. We chose the fans, as all had high bromine levels (5.3 and 7% by weight). We were able to identify the exact chemicals (and their levels) that made up of a small part of the total bromine – and this included the decaBDE that HP had claimed to stop using – as we said, there are other forms of brominated chemicals that contribute to the total amount of bromine.

    TBBPA – as we said, TBBPA is commonly chemically bound into plastics, and therefore it is not able to extract and test for it. The levels of TBBPA monomer found (and the far higher total bromine levels) may indicate the incorporation of TBBPA into the plastics at far higher levels.

    For both TBBPA and PDBE, as we said; “it is not possible to obtain any further information as to the chemical nature of the majority of the detectable bromine content in the fans using the methods employed in this study. To obtain such information by analysis is likely to remain very difficult, such that the only option may ultimately be to request such information from the component manufacturers themselves.” Why don’t manufactures provide consumers such information?

    Keith Ripley says we could not tie the high bromine levels to the ‘brominated flame retardants we said are of highest concern’. We gave the environmental & health issues of the BFRs we were able to identify, and some are of high concern. The EU now restricts nonaBDE, one of the PBDEs we found. We don’t know what other forms of brominated chemicals have been incorporated, we could only surmise. So we cannot say if the other chemical forms that make up the majority of the bromine are equally of concern, are safer, or pose even greater risk, or even if they are safe to use. The one thing we could and did say is their presence gives the potential to generate yet more hazardous chemicals upon disposal.

    “The amount of PVC was low” – The results demonstrate our call for substitution. It is great that some wires do not have PVC coating, this shows it is not necessary – so why is PVC used for others?

    Many of the pollutants we discuss in the report are persistent in the environment. Keith questions if they are a risk outside where the products are dumped or recycled – should we ask Artic polar bears if they object to the PBDEs in their blood as a result of sources far away? International agreements such as the Stockholm Convention that addresses persistent organic pollutants have been created for the very reason that global pollutants do not stay in the country where they are emitted to the environment.

    ———————————-

    This was my reply:

    I am glad that Greenpeace decided to officially respond, and that in doing so, they largely stuck to being civil and more or less substantive. They didn’t address all the issues I raised in my guest blog on Treehugger, however. But I’ll get to that in a moment. First let me respond on the points they did address.

    Greenpeace references to ewaste in China and India is because we have visited these recycling yards, where we found evidence of large amounts of ewaste from US, Europe and Japan being recycled in primitive conditions.

    Yes, large amounts of e-waste from the US, Europe and Japan are being recycled in primitive conditions in China and India, and yes that is of concern. But why is Greenpeace not publicly calling on the carpet the governments involved — national and local — with ferocity at least as equal as that they apply to some of the manufacturers? Why isn’t there a mock website about India and China, instead of just one targeting Apple? Given China’s recent attempts to appear “green,” perhaps you should call them out. Both of those nations ratified the Basel Convention and China claims to have applied the Basel Ban since 2001 — why not call them out on e-waste the same way Greenpeace got Brasil to ban imports of lead-acid batteries for “recycling” (artesanal mining) several years ago?

    The practices and conditions you witnessed in China and India are probably illegal under national law there. Did you report them to the proper authorities? Some of the workers in the Greenpeace video I saw looked underaged. Did you report that to labor authorities?

    If concerned about the welfare of those workers in the “recycling” operations, why aren’t you doing your utmost to see them shut down and to block the creation of new operations to take their place? If doing your utmost, why don’t we hear about it as much?

    UNEP has also evidence of e-waste dumping around the world at:
    http://www.grid.unep.ch/product/publication/download/ew_ewaste.en.pdf

    Actually, I’ve read the the UNEP report you cite, and it produces no new, independent evidence of such whatsoever. The information and graphic used are derived from reports provided by NGOs, including Greenpeace. By the way, the graphic used in the UNEP report, based on NGO submissions, is then cited with UNEP give as the source in the Greenpeace report you cite. Isn’t that recasting the data?

    With respect to testing of laptops, yes the sampling was limited – it’s very time-consuming and costly and highly technical. We demonstrated that even from such a limited study it was possible to find toxic chemicals (including those manufacturer had claimed to stop using).

    The sampling was very limited, but the conclusions drawn in the accompanying PR (the report itself was more qualified and nuanced, but still) were quite broad — too broad for a sampling size of five units bought in two countries.

    Frankly, since you are a scientist I am surprised that you are trying to defend the claims made on behalf of such a limited study from which no meaningful conclusions can be drawn and whose design and selection criteria are anything but transparent. For any other type of product, could you have tested only five random samples from two countries and from there extrapolated sweeping claims about product composition and toxicity for an entire sector in the global marketplace, and still be taken seriously?

    I think that if you are going to test these products and make claims about their average composition and hazards, you need to design a more meaningful study. For example, if I buy five samples of a food product in two countries and find lead concentrations in one of them, can I conclude that all brands of that food are toxic? If I bought five oscillating fans from Belgium and Sweden, and found that one of them had lead solder and PVC-encased wires, could I then claim all oscillating fans on the marketplace worldwide are laden with toxins? That, in essence, is what Greenpeace did in the publicity it issued in conjunction with this report.

    Testing is “time-consuming and costly and highly technical” ok, but if it is a question of resources (personnel, man-hours, cost of electronic purchases, lab services, etc.), then why doesn’t GP take up my suggestion of teaming up with experienced product testers in multiple countries so we can get a more meaningful sample?

    BTW, one has to wonder if laptops, because of their compact structures, might have been far more costly and time-consuming to test than, say, desktops, or printers, or TVs, or… so why laptops first?

    In the case of HP, although HP claims on its website that it has not used one type of brominated flame retardant – decaBDE – for years, testing of this one model showed this statement to be false.

    Yes, and you downgraded them for it, and I gave you points for keeping your promise on that from your Greener Electronics (review my posts again, you’ll see it). Two points here, though: (1) are you certain this is not an isolated case? On what basis? (2) Acer and Apple were found to do better in their components than the “Greener Electronics” report supposed, yet they were not given credit for it. Why not?

    No cadmium or mercury was found – yes, but other toxic chemicals where identified.

    You brush this aside as if this is a minor issue or find. Given the toxicity of these heavy metals and how much of it has been in electronics in the past – and still can be found in many electronics outside of Europe and North America – it is not.

    Lead was found at 4.5% – 13% – lower than in some electrical solder, but 45-130 times the RoHS limit for lead (RoHs didn’t apply to these models, but is a useful benchmark).

    The fact remains that lead was only found in ONE of five models – the same model that contained the decaBDE. GP knows all too well that it was no small matter for the industry to remove lead from the solder in computers. So why not applaud the four out of five manufacturers that complied with this RoHS requirement ahead of their legal requirement to do so. This is something I have never understood about Greenpeace – the quickness to condemn bad behavior before proof is in, the reluctance to praise good behavior even when evidence is before you.

    We analysed for a range of BFRs. No we didn’t find every single chemical we looked for, but we didn’t expect to. This shows that hazardous chemicals can be phased out – as far as we know PBBs are not now incorporated into products (though we wanted to check – you never can be sure that you are given correct info)

    Only traces of TBBPA /PDBEs – we found high levels of bromine at 0.19% to 9.4% (that’s almost one tenth by weight of bromine!) in around a quarter of all the components and materials tested. Bromine levels are indicative of BFR levels, though do not show the actual chemicals.

    I hope that when you design your next materials test of electronics, that you do with an eye to identifying what BFRs are actually present and in what quantities. I too am concerned about BFRs, even if they have not yet been added to the Stockholm Convention controls or LRTAP Protocol. Bromine levels suggest BFRs, but do not indicate them. Let’s prove the link, not just suppose it.

    TBBPA – as we said, TBBPA is commonly chemically bound into plastics, and therefore it is not able to extract and test for it. The levels of TBBPA monomer found (and the far higher total bromine levels) may indicate the incorporation of TBBPA into the plastics at far higher levels.

    Yes, but TBBPA is not yet restricted by the EU’s RoHS Directive, nor a major national government. Until it is or looks close to being banned, we’ll probably see a slow phaseout of TBBPA. Speaking to this report, can you realistically expect to find zero levels of TBBPA in nations to be governed by the RoHS Directive (which, after all, is where you chose to buy these units tested)?

    To obtain such information by analysis is likely to remain very difficult, such that the only option may ultimately be to request such information from the component manufacturers themselves.” Why don’t manufactures provide consumers such information?

    I think manufacturers do need to provide some disclosure over the heavy metal and POP content of their products. The last couple of decades have shown us several cases where disclosure to consumers and shareholders sometimes moved firms to make changes in their products and practices faster than regulation ever did. The question is, what is the most meaningful form and medium? And I mean meaningful not just for GP, SVTC or BAN, but rather for all stakeholders, including (perhaps especially!) John Q. Public.

    The one thing we could and did say is their presence gives the potential to generate yet more hazardous chemicals upon disposal.

    A couple of points here. First, outside of the rogue recycling operations you keep pointing in China, India and perhaps Nigeria, studies suggest that in most nations end-of-life (EOL) electronics end up in dumps or landfills with common household trash, or in some cases, in “temporary” storage in garages or sheds or other storage spots.

    Second, even if we could wave a magic wand and eliminate every iota of heavy metal, PVC and BFRs in all new and used laptops in the world, in all likelihood as long as the conditions and practices GP describes persist in the Chinese and Indian and Nigerian “recycling” operations, the health of the workers and surrounding community will be at risk from something else they burn, crack, shatter or otherwise manipulate improperly and against commonly accepted guidelines.

    Do you know of many things in electronics (or a plethora of other consumer products) that DON’T release toxics when burnt in the manner those artesanal recyclers use??? Are we to design all our products on the basis that someone somewhere may ignore common sense, recommended practice and laws, regulations and guidelines and burn something they should not?

    So how do manufacturers design electronics (or other products, for that manner) to prevent the careless from hurting themselves and their co-workers and companions?

    And should that be their design priority, in truth? Shouldn’t we instead be asking them to focus on making their products easy to recycle by properly licensed and trained recyclers? To substantially reduce their power consumption? To increase their useful product life, and make them easier to “improve” through modular upgrades rather than tossing out our entire computer or other electronic every two years?

    “The amount of PVC was low” – The results demonstrate our call for substitution. It is great that some wires do not have PVC coating, this shows it is not necessary – so why is PVC used for others?

    Again, PVC is not banned by the RoHS directive or any major national law, so the manufacturers likely will phase this out slowly. In fact, your report showed that they are taking the initiative – why not applaud it? Can you realistically expect total and swift elimination of PVC wire coatings right away, absent a regulatory imperative?

    Keith questions if they are a risk outside where the products are dumped or recycled – should we ask Artic polar bears if they object to the PBDEs in their blood as a result of sources far away? International agreements such as the Stockholm Convention that addresses persistent organic pollutants have been created for the very reason that global pollutants do not stay in the country where they are emitted to the environment.

    Well, you kept it civil and largely substantive to a point, but couldn’t resist a parting shot, eh?

    Are these PBDEs controlled under the Stockholm Convention? Not yet.

    The polar bears are endangered by PBDEs released from laptops? That’s quite a claim to throw out; I’d like to know more. What study has traced it to laptops (the subject of this study, right?) as the sole or major source? Are laptops really the sole source of BFRs (more so than televisions? Or electrical equipment?)? Or, for that matter, are electronics the sole source, or even the lion’s share? What about textiles? Insulating foams? Office equipment? Plastic housings for other items? Polystyrene production? Foams used in upholstered furniture? Is Greenpeace designing reports and mock websites for these products too?

    If there is such a clear linkage between the polar bear problem and PBDEs, why haven’t they been banned from electronics yet?

    Let’s be clear here: I believe PBDEs and other BFRs may be classified and controlled as POPs, and eventually be listed in the RoHS Directive and national laws. They are of concern (I worry about the studies I read about their presence in dust and the food chain). But please – skip the gratuitous polar bear zings and make that case more seriously.

    —————————-

    Now to the points the Greenpeace response avoided or did NOT address. First and foremost is TRANSPARENCY. GP still does not reveal why those five models, why those five companies, why those two countries, were selected. Or for that matter, why laptops instead of other electronics. Why is that?

    I have to wonder about the priorities and sense of proportion here, too. While perhaps not nearly as sexy as attacking MACs and I-pods, in terms of real and present hazards to human health and the environment, shouldn’t GP focus first and more loudly on mercury switches, improper handling of lead-acid batteries, hazardous materials in end-of-life vehicles, the extremely high mercury content in “Chinese batteries” that one finds in every kiosk and small store throughout the developing world? These are far more likely to affect more people worldwide than the laptops GP has chosen to highlight.

    If electronics is for some reason more important than all these issues, why laptops? Look at the graphic on page 2 of the UNEP document on e-waste you referred us to. 50% of WEEE is from household appliances, not laptops. 15% is from IT and communications equipment, 10% from TVs, 10% from monitors. So, if your concern is RoHS and WEEE, why do you ignore 85% of the e-waste and focus on less than 15%? And you doubtless know that the amounts of toxics in other equipment taken together is far greater than those in laptops, and that those products are far more ubiquitous throughout the world than laptops (which, after all, are still in a small slice in the market).

    So why laptops as first target? Perhaps you have good, sound, technical reasons for it (can’t be the cost and ease of testing!). But nowhere in the Greener Electronics or laptop toxics report have you made that case, so their selection does not seem to be linked to realities on the ground.

    If top priority is to make electronics recycling safe for the informal recyclers operating in places such as India and China, you can take out all the heavy metals, BFRs and PVC you wish from electronics, and they will still put their workers and surrounding community at risk because of their practices. Those practices must be addressed more vigorously.

    If the problem GP wishes to address is EOL electronic exports that avoid proper treatment and disposal in industrialized countries, shouldn’t they focus principally on changing the Basel Convention treatment of EOL electronics?

    And let’s keep perspective here. Even if manufacturers succeed in phasing out all the substances GP says are of concern, the old electronics containing them will be floating around in the marketplace and eventually ending up in landfills or those artesanal “recycling” operations in developing countries. If GP and its allies do not spend equal time getting those operations shut down, educating those people about the health and environment risks, and forcing those local governments to do their jobs (protect their citizens), how have they protected those people they speak so frequently and fervently about? Their children, perhaps, after all that old equipment with the materials of concern works their way through the system, but not the people GP uses as its rallying cry today.

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