Draft technical guidelines on e-waste

Comments from PC Rebuilders & Recyclers, LLC, USA(additional comments received on 26 June 2011)

Here are my comments on the 21 February, 2011 document:

1)Paragraph 9: I think it is inappropriate to characterize the motive of the exports to be “very often” without any citation or research.

2)I object to the inclusion of paragraph 10. These numbers are pure guesses and the second paper only refers to the previous BAN reference. I believe that such a controversial reference should be excluded from an otherwise authoritative document.

3)In Paragraph 12 I think that molybdenum should be exclude as a material recovered in recycling. Only rarely is that material recovered. This kind of casual reference leads to an erroneous conclusion that material recovery or recycling is efficient when it comes to critical or rare Earth metals.

4)In paragraph 13 I think it is misleading to state that “reuse can also have a negative impact if not done properly.” Reuse most always has a better environmental impact. I believe the author was trying to suggest that there are exporters that pretend to be sending equipment for reuse but in reality it is going for other purposes. I would appreciate this language being clarified.

5)Further in paragraph 13 in the last sentence I would like to request that the word “frequent” be replaced with the word possible. Electronic manufactures have taken great pains and will continue to take great efforts to reduce and eliminate Annex VIII and Annex IX materials and properties.

6)I would request that the footnote on the bottom of page 7 exclude “they were designed to perform” at the end of the first sentence. In the case of IT equipment this adds a level of complication that would exclude appropriate reuse and therefore not uphold the objective of environmentally sound management. (see also comment 10)

7)Paragraph 26 b) should exclude the phrase “on every item.” There are appropriate times that rigorous scientific sampling protocols should and can be applied.

8)I disagree with paragraph 28 b). There are appropriate times when a desktop computer that is fully functional but it will not have a hard drive. This equipment may be repurposed as a “thin client” device that no longer needs a hard drive as it was originally designed. It can be tested to validate it is fully functional

9)Is it true that all Parties “consider used equipment destined for repair or refurbishment to be waste?”

10)I have trouble with the second half of the definition of E-waste because it is not possible to know if “the last owner has discarded with the view of its disposal.” If I am looking at two identical fully functioning LCD displays or any other device in a container that is about to move across a national boundary there is no possible way I can impute the intent of the last owner. In the US the average hard drive is only used for 40% of its designed life not because of lack of functionality but rather it has been replaced by new technology. How can I possibly know if a hard drive that has been used for 20,000 hours but designed for a mean time failure rate of 50,000 hours was discarded with “a view of disposal.”

Thank you for the opportunity to comment on this document.

Willie Cade, CEO, PC Rebuilders & Recyclers, LLC., Home of the Computers for Schools Program

3053 N Knox Ave., Chicago, IL60641, Office: 773-545-7575, Fax: 773-545-7502, Cell: 773-562-3377