Geography Baiting 4: BAN Investigates Un-American Recycling Activities

Well, this guy must not be a credible source...

"Just a few days after arrival, the printer left Vermont and travelled to the Chicago area and then onwards to the port of Long Beach, California. It next pinged off of the coast of mainland China before arriving at the port of Hong Kong. Two days later it was in Mr. Lai’s Farm. " - Jim Puckett

He's talking about ME.

Sounds very "Un-American".  Sounds like Evidence that we are exporting 40% of our waste, according to BAN.  Or worse, sounds like companies that PAY the NGO tribute money are a "safe" solution to the Un-American problem, we must be shipping more than 40% just to buck up the average.

Caution:  Wet Taint

Sounds like.  This NGO makes a lot of noise, but the report they issued says in one place that 50%-80% of devices are exported, in another place over 80% are exported, and in the press release says 40% are exported.  In Geography Baiting #3 we showed what the actual MIT data say, and when corrected for the sampling error (not GPS tracking the 60-80% of e-waste that's almost never exported), what they actually have is data that is pretty close to the 7%-15% range of other vetted studies.

But this is about sound.  Jim doesn't want people to listen to me, he wants to discredit the blog.  So he's got a GPS on a device purchased by an R2 Company in Hong Kong, traces it to an R2 Company we sold it to in greater Chicago, and traced that back to us, who was downstream for our client in greater Boston - the one with no public drop off point - who someone told MIT undergrads to deposit the normally reuseable laser printer they were told to sabotage inside.

They did probably expose something we didn't know - that the buyer of our buyer in Hong Kong is using Hong Kong EPD's non-chemical non-hazardous waste classification of printers to outsource those devices on the cheap.  That's information, and we began acting on it last May.


But the "Geography Baiting" is making all Asian recyclers - all "Un-American" recyclers, seem primitive.  Telling readers that what happened to Robin could happen to you.  If a device might be reused, might be repaired, but someday eventually gets disposed, it will impugn you for doing business with someone who does business with someone who does business with someone overseas in the first place.  That is why they name the client in greater Boston, who is 4 transactions away.  

We do allow some printers to be exported.  Not very many.  Less than 6% of the printers that arrive at Good Point Recycling are intended or approved for reuse, and it was one of those BAN tracked to the R2 buyer whose R2 buyer sold it to someone at MLPF. 

Our problem at Good Point is that we believe in, and want to support rather than boycott, the best practices and state-of-art recycling in emerging markets.  We now know that the downstream 2nd tier audit didn't tell us everything, but we'd have no more info about that than if we had used an E-Stewards company, and BAN/MIT have not demonstrated that E-Stewards is superior to R2 in their study.  (But look at how my pal Craig Lorch is portrayed in an inset, compared to me).


What we refuse to do is play a role in the racist campaign to impugn Geeks of Color in other countries.

They are not "collateral damage" because they are, by BAN's definition, the TARGET.  They are at Ground Zero.

Perhaps the saddest "collateral damage" are the university students and journalists who drink BAN's Kool-aid, and believe that racially profiling and impugning "un-American" recyclers overseas is helping the environment. Or perhaps, like all of us, I empathize more with them because they are from the same society and geography that I am.  That's how environmental injustice happens, that's the root cause.


Inline image 1
5 Years of Printers at Good Point

The text in BAN's report is carefully worded to imply my company shipped the device to China - something he was called on weeks prior to releasing the report.  We shipped via USA domestic trucking firm to three R2 or E-Steward certified recyclers in Chicago area that Quarter.  ChicagoDestination1 shreds, ChicagoDestination2 shreds domestically, and R2 Certified Recycler ChicagoDestination3 does identify R2 facilities in Hong Kong - and also demonstrates REUSE capability (the other two did not).  We shipped a "red" reuse printer to Chicago3.

[Note:  The 5.9% in red constitutes printers we did not either crush to determine as scrap or send to zero reuse company.  The 5.9% weren't necessarily reused or exported.  We thought they might be reuseable but we didn't make final determination, as we did the other 94%.  The Q1660a printer BAN sent sells refurbished on Amazon for over $200 - how BAN chose to send us that one, rather an obvious scrapper, is one of our questions.  We did not toe-tag the 5.9% as waste because they might not be dead yet.]

My company is highlighted or "profiled" as an "un-American" recycler despite the fact we never loaded a sea container, and we provided all the diligence and were able to correctly predict the 2 recyclers downstream of us - who we can find out if they "dropped the ball" only if BAN un-obscures  100% of the geographic data!  This is a Bilbo-Baggins-Riddle --- what data does Tailgunner Jim have in his pocket?

What I'm doing is channelling Pete Seeger.  Sure, I could push the Chicago Recycler #3 under the bus.  By attacking BAN and MIT Senseable City Lab's methods and conclusions, I left Tailgunner Jim only one choice - to go after ME, by name.

Simple response "No we didn't export it, we sent it to another USA recycler, therefore why are you profiling me rather than the exporter?"   Harder question: "You've done enough. Have you no sense of decency, sir, at long last? Have you left no sense of decency?"

Maybe I'm not the right guy for this role.  I'm no Senator Welch.  But all of us one day will be called on to push the profiled scapegoat under the bus, and on judgement day, I hope to say I did the right thing.

Here is email about the subject with Jim Puckett of BAN a few of weeks ago [exerpt below]:


Aug 15
In response to the first email from Jim Puckett:  
JP "As you no doubt know by now, one of our trackers was placed inside a non-functional printer and delivered to a company called xxxx in Massachusetts.  It subsequently went to your facility in Middlebury and then was exported to [ChicagoDestination3] in the Chicago area... We have seen your letter to MIT where you admit to this export.  However, you seemed to believe the device went to xxxx.  It did not.  It went directly to New Territories and an unpermitted facility that practices what I am sure you would agree is substandard, dangerous recycling.  We have a lot of photos and footage of his location as does PBS in Seattle, HK01 Newspaper in Hong Kong and others." 
[note: "exported" to Chicago??? note his answer below}  Note:  the letter did not say we seemed to believe it went anywhere, we didn't export it, period.  The letter pointed out to a half billion dollars in reputable facilities, and that BAN was obscuring all the destinations for all the items imported to Hong Kong, and that their "conclusions" seemed inappropriate if any of them might be properly recycled.}

From: Robin Ingenthron

Date: Tuesday, August 16, 2016 at 9:35 AM

To: Jim Puckett

Cc: Josh Lepawsky, Joshua Goldstein , Carlo Ratti

Subject: Re: Question


Dear Jim,


Thank you again for reaching out to us, and for responding to a few or the questions I posed last night.  To be clear about our correspondence last night, I am not sure by "letters" whether you are referring to the letters sent months ago to Carlo Ratti or to the two emails we sent last night.   We need to make clear several points:

1.      Our client in XXXX MA is not a public drop off.  They collect solely from private companies and individuals.  

JP: This is not really relevant to the question posed.
note: the question we posed in the letter is how did BAN / MIT randomly distribute, deploy, or select the sample? 
2.      Material we shipped from Middlebury by truck to Chicago [area] was not "exported to Chicago"; the choice of the word "exported" appears intended to create a perception of legal liability that does not exist.


JP: Yes it’s a poor word choice if we indeed used that somewhere.  

[note:  "you exported to Chicago" is a direct quote from JP's preceding email]


3.      Material from Chicago to Long Beach may have contained our material, intact or not.  We don't dispute that, though we don't know what exact information about the device (printer).  Our letter of May 2015 explained to MIT why this information is necessary and vital, and certainly more explanatory than the race or culture of the people who purchase it.


JP: I will send you the coordinates we relied upon for the tracker enabled printer that went through your facility.


4.      Our Chicago area recycler has provided records of destinations in Hong Kong which you claim is incorrect - but you have obscured the data.  

JP: I will send you the coordinates.

5.      You have provided data obscured to our company to companies which pay BAN money.

JP: I am not sure what you mean and I am not sure of the relevance of this statement to the question at hand.

note:  We specifically notified BAN in the MIT letters and emails that Total Reclaim of Seattle, an E-Stewards donor, was given weeks if not months to meet with BAN, review data, and prepare a response.  We believe another local competitor was also given advance access to the study, which is why I'm not being specific.  This may be "ok" for BAN but vioilated MIT Ethics Rules and MIT needs to remove its name from the "joint study" if this occurred.


6.      You have solicited payment from my company.


We have?  Not to my knowledge.


Note:  Seriously?  See MIT Ethics Rules, MIT needs to remove its name from the "joint study" if this MIGHT have occurred!   


7.      Your email states that toner is found at the location in Hong Kong where our material was received, but our material was shipped toner free, and we can prove that.  You did not ask whether we remove it.


Again this is not relevant.  We never stated we found toner from your printer.  The point being made here is that the site was a highly polluting operation which no reputable recycler would be proud to claim as a downstream.


Note:  BAN explicitly states Toner as a reason not to have exported the printer in its report.  BAN also states "leaded solder" but sent us a ROHS-compliant leadfree printer.  Making it up as they go? 


8.      You have stated that "child labor" is used in the New Territories, which we find to be an incredible claim, not supported by any visual evidence.


Never said this actually but its irrelevant to the question at hand.  I have actually said the opposite.
note:  "..is routine as is the use of child labor to accomplishthese tasks."  [Exporting Harm, 2002]

9.      The children in BAN's recent press releases, we note, were photographed a decade ago, and to make a claim that our clients material was processed by children is alarming and outrageous and demands proof.  Is this occurring, or are you speculating?


Not sure which press release you are referring to.
Note:  Have to give him that, since they are on practically all BAN press releases. 


10.  The claims about child labor are shocking to us and we will definitely pursue them legally with our downstreams but we are confused that there is no evidence or citation of child labor anywhere in Hong Kong in your report.   There is speculation that a yard in Hong Kong will dump printer scrap out of a container onto the ground in order to put it back into a container for transshipment to mainland China, but like the claim of Child labor (which has been illegal for almost a century in Hong Kong) there is no evidence at all.  Did BAN track our device out of Hong Kong, to a place with child labor?  Again, it appears to be a declaration intended to permanently damage my company's reputation.


Again not relevant but it’s a claim we never made with respect to Hong Kong.  


BAN repeatedly links New Territories of Hong Kong with Guiyu and "Exporting Harm", and claims in this report that "hundreds" of sites like Mr. Lai's Printer Farm [MLPF] exist in the New Territories.  Hundreds.  But doesn't show the $550M Eco Park project, and only shows the one a small fraction of the facilities which manage non-chemical scrap printers.

There was only one category, representing 5% of the printers we have managed, which BAN tracks to Hong Kong, so we focused on that downstream first.  And no doubt non-repairable printers went there as well, for parts recovery or manual disassmbly, which is why we required [ChicagoDesination3] to ship only to R2 facilities in that country, and why we obtained written evidence that focus material circuit boards (even if our device was RoHS) were in fact recovered for proper recycling.

But there were other printer scrap trailers my company sent to [ChicagoDestination1, ChicagoDestination2] in much higher volumes in the Chicago area, so we needed data complete our diligence, and asked for it last May.  Again, it's evident that had we donated to BAN by joining E-Stewards, we would have been offered all the data in advance and a chance to get our position straight.  Perhaps because we were not a donor, this information was held from us from May to September.  There may be another explanation why E-Steward companies who exported (not just exempt printers) to Hong Kong got this special access to the data, Jim doesn't answer the question and denies soliciting us to join E-Stewards "to his knowledge".  Which is of course a lie.

We provided MIT and BAN OUR information (total shipments to domestic vs. foreign destinations), specifically for printer scrap and for anything else requested, to Dr. Carlo Ratti of MIT.  Jim Puckett of BAN confirmed he received it, and sent emails specifically citing that information.

So given that BAN knew the following prior to publishing their document:
  1. My company did not export the printer, 
  2. We sent it to a domestic USA recycler in Chicago, 
  3. We sent to that recycler the laser printer selected for potential reuse, 
  4. The other 95% were sent for domestic shredding, 
  5. We verified that Hong Kong EPD does not consider the printer hazardous chemical waste, 
  6. We verified takeback of focus material circuit boards from all identified Chicago recycler downstreams in Hong Kong prior to shipping,
  7. We requested specific information about the printer in May hidden by MIT/BAN 
  8. We requested all destinations in Hong Kong stop being "obscured"
  9. One Hong Kong destination we obtained OUTSIDE of MIT and BAN (through another recycler) did indeed show their device (an LCD) was sent to Hong Kong's ECO Park and appears to be in second use in Tin Shui Wai (in Yuen Long NT, where BAN says our printer went)... 
Based on all these steps, we began researching both the story provided by the 3 Chicago area recyclers (one of whom identified Hong Kong as a possible downstream, which we checked) and the story provided by BAN and MoniTour, and posted our questions by blog.

So why, out of 168 recyclers, did BAN select me - not a direct exporter, who has provided all the information necessary on our end, and has requested information on their end - why pick Robin Ingenthron to quote and focus in the article?  And why was the language at top (like the destinations in Hong Kong) obscuring information that our shipment was sent by USA tractor trailer and unloaded at a Chicago recycler?  Why not make the Chicago company the focus of page 32?  

Please?  Does anyone doubt what is going on here?  Does MIT not now see EXACTLY what we warned them about in May 2016 about this partnership?  Has MIT by now NOT questioned Dr. Randy Kirchain, Dr. Jeremy Gregory, Reed Miller at MIT?  Has MIT Ethics Committee now noticed the names and pictures of MIT student undergraduates in the report?

As everyone can see from the correspondence, Jim Puckett had the information we provided to MIT in May, knows my company did not "export the printer" to Chicago, and is using the fact we had done diligence on the other 2 tiers of downstreams to infer culpability on us and our client.

At long last, have you no sense of decency, sir?

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