[FreeGeek] "BC Computer Reuse Standard"

[Ifny]

Greetings Geeks,

This was our official response to RCBC's draft proposal for computer reuse 
standards. It can also be viewed on the wiki at 
http://wiki.freegeek.org/index.php/Response_%28draft%29

You can view RCBC's draft proposal documents here:
http://wiki.freegeek.org/index.php/RCBC_proposed_%22BC_Computer_Reuse_Standard%22




Re: RCBC Computer Reuse Organization Standard

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

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

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


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


A. Pledge of Stewardship

We will address each item individually.

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

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

3. We agree.

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

5. We agree.

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

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

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

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


10. We agree.


B. Residual Lifespan Criteria

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

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


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

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

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

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

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


C. Implementation Plan

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


D. Conclusion

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


Appendix. Commentary from Basel Action Network

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


Basel Action Network maintains that:

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

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

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

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