Why Canada needs more meaningful measurements

Why Canada needs more meaningful measurements

By Clarissa Morawski

Oct. 17, 2013

Last month CM Consulting released the first "Canadian WEEE Report 2013," which documents how, what, and how much e-waste is collected in the nine Canadian provinces that have enacted regulations since 2004 when the Province of Alberta launched its program.

"The WEEE Report 2013" describes the management of end-of-life electronics in Canada and offers important considerations for planning for the future — a future in which electronic waste will be quite different from what it is today.

Measuring Performance

Measuring the performance of provincial electronics recycling programs has been limited to indices of program results, such as tonnes collected for recycling per capita and, in some cases, the capture rate. Although such measurements are useful, the information they provide is void of any real meaning in terms of program performance.

To start with, weight measurements offer no information about the composition and toxicity of WEEE, nor do they take into consideration that weights of products are constantly changing. Recent trends toward producing multi-function electrical and electronic equipment, as well as toward light-weighting products and miniaturization, suggest that, over time, overall WEEE tonnage will decrease.

Cost comparisons are also meaningless in relation to program effectiveness because all of the programs are different. Ontario, for example, has the lowest cost per tonne compared with other provincial program, but this may not necessarily be a good thing.

Ontario's lower costs may be the result of reductions in stewardship fees made to processors. Our report further points out that one of the reasons stewards are paying lower fees to processors is their new collective service provider selection criteria. Built into the procurement selection process is a scoring template based on a number of factors including costs, recycling efficiency and transport. When the program plan was approved by the Minister of Environment in 2008, the importance of recycling efficiency in terms of scoring was weighted 50 percent, but today it is a mere 20 percent, with 55 percent of the score now allotted to cost (this is up from an original 20 percent in the first approved program plan and then 30 percent in the revised program plan).

While the "WEEE Report 2013" does provide a series of up-to-date cost and weight-based performance indicators by province, the report also suggests other ways to measure WEEE and explores the regulations and standards surrounding WEEE recycling. The report concludes that while the management of WEEE in Canada has certainly evolved and is continually improving, measurement of collection/recycling and standards for primary and secondary processing plants need to improve.

Measuring the real benefits of WEEE recycling

We know that life cycle assessments consistently show that the greatest environmental benefits in material management are derived from those systems that keep the material in use longer, thereby replacing virgin material extraction and production for as long as possible. Each time virgin metals and elements are replaced with recycled raw material, there is a significant reduction in pollution, greenhouse gas emissions, and energy consumption. Metal recycling derives the greatest environmental benefits compared with recycling plastic and glass products.

These benefits suggest that the output of the recycling process offers important information and can determine the environmental merit of the collection program.

The WEEE Report 2013 defines five performance rates and explains that the benefits of recycling are found in a closed-loop system where a material can be continually recovered and used as substitutes for virgin metals. Material that is not collected for recycling but rather used in a manner in which the functionality of the end-of-life of the material is lost is excluded from the recycling rate.

If this definition is extended to other materials found in WEEE, then knowing the fate of the recyclate from WEEE processors (or the flow of materials) to the final point of disposition will further inform program performance.

Tracking our WEEE
Ensuring the proper management of WEEE is important to everyone. Manufacturers of electronic products are heavily invested in their technology and want assurance that the programs and service providers managing their products at the end-of-life stage are considerate of environmental health and safety.

Consumers that purchase and use electronic devices and participate in WEEE collection schemes assume that their e-waste will be handled properly, without risk to human health or the environment.

Finally, processors and recyclers of electronic products and scrap materials count on fair operating requirements, which protect workers, promote innovation, and foster a competitive marketplace.

However industry and media reports of substandard downstream WEEE operators in developing countries such as Africa, India, China and Pakistan continue to emerge on a regular basis. For primary processors and program operators, weaker environmental regulations and monitoring in other parts of the world make it difficult to weed out the legitimate operators from the bad operators who exhibit little consideration for health and safety and environmental protection.

Due diligence

Performing due diligence should be the responsibility of both the primary processor and the program operator, but the level of due diligence carried out by each may vary. Consequently, requirements and expectations should be clearly outlined in the standards and leave little room for interpretation.

Most stewardship programs in Canada use an industry-developed processing standard called the Recycler Qualification Program (RQP) that by all accounts is a good standard on paper, with room for improvement. The approval process is lacking in some areas, like approving downstream vendors in countries like China, India and Pakistan without on-site audits.

The RQP was developed by industry to fill a void of standards from government. Ideally, standards should be overseen by government or an independent third-party to avoid the proverbial "fox in charge of the hen house" scenario, which is currently the case in most programs in Canada (except Alberta).

Institute for Electronic and Electrical Engineers (IEEE) in their own 1680 series standard, which is considered as the de facto standard, state that where the manufacturer has control over the choice of service provider the certification body for the service provider must be independent of the manufacturer to avoid any conflict of interest.

WEEE managed outside of stewardship programs are generally not subject to the RQP standard, setting up an un-level playing field for WEEE processors. But this too is for the provincial governments to deal with by regulating a WEEE operating standard for all e-waste managed in or exported out of their province.

We still have a long way to go to ensure that all the facilities and workers that handle our e-waste, in Canada or abroad, maintain high operating standards with independent and regular verified auditing based on measurements that are meaningful.

Clarissa Morawski is the principal of CM Consulting and can be contacted at clarissa@cmconsultinginc.com.

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