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2006-05-04
Why the UK WEEE directive is not viable
The first thing you notice when you arrive at the CKS Group?s facility based at Rushden near Wellingborough is how clean it is. The place is spotless and just about as far removed from your archetypal waste treatment facility as can be possible. Of course as a specialist in recycling and remarketing IT equipment and WEEE compliant electronics recycling, the group is the first to point out that it is not a run-of-the-mill waste disposal company.
?Within this facility, we focus on meeting the needs of business users, who are driven by a desire to see a return on their redundant assets? explains David Sutcliffe, CKS?s sales director. ?To fully realise those returns we need to treat everything that arrives at our door as an asset rather than waste, and to understand the potential value in those assets requires every senior manager in the company to have an IT and electronics background, rather than a waste management background.?
The group?s involvement with WEEE has been a quick, but natural progression. Initially CKS were involved in the supply, refurbishment and maintenance of high-end audio-visual equipment. The main corporate customer at the time, Nationwide Building Society, suggested that the service be expanded to cover their desktop IT assets.
?When you first think about it there is a lot in common between display and computer technology,? recalled Mr Sutcliffe. ?However, from the outset we were struck by the significance of the role computers had as a platform for corporate and private data. The electronics may be similar, but addressing the confidentiality needs of business users was our primary concern. Without effective data deletion options reprocessing for resale simply wasn?t a viable solution. Further, data deletion methods needed to be backed up with detailed audit trails and insurance to indemnify customers against future claims.?
The demand for specialists such as CKS who recover value from redundant equipment is huge and growing all the time. Its Rushden facility alone processes over 120,000 systems a year, 75% of which enjoy a second or even third life in use.
Whilst CKS is focussed on waste avoidance and appliance recovery first at Rushden, it is continuing to expand its downstream facilities into specialised component and materials recovery and recycling through the development of best practice treatment facilities for end of life IT and Telecommunications equipment (Category 3 WEEE).
?The data issues are no different at end of life, and nor are the disassembly requirements under Annex II of the WEEE Directive,? explains CKS Practice Director, Derek Morgan. ?Coming from a life extension background we have already mastered the processes and reverse engineering requirements that are expected of modern waste management facilities. These requirements are not natural for traditional scrap and shred metal merchants and companies want the assurance that the buck will stop with us. That?s what we deliver, assurance and insurance.?
There is no doubt about the demand for the group?s expertise.
A year after CKS started trading in 1997, it was estimated that of the six million tonnes of electrical equipment waste arising in Europe the potential loss of resource comprised 2.4 million tonnes of ferrous metal; 1.2 million tonnes of plastic; 652,000 tonnes of copper; 336,000 tonnes of aluminium and 336,000 tonnes of glass.
The rise in demand for WEEE specialists has meant the company is about to open a new plant in the south of the UK to offer its own high security disk shredding and WEEE compliant recycling services. With an initial capacity of 250 tonnes per week, the company says it will accept unusable brown goods, IT and telecommunications equipment for disassembly, component removal and material separation for reuse or recycling.
?We have plans to increase capacity to over 750 tonnes per week, concentrated mainly on Category 3 WEEE. Further, our upstream operations are also set to grow and we have already secured planning permission for an expansion of our facility at Rushden. I am confident that CKS is well on its way to becoming the most comprehensive and secure electronics recycler in the UK,? says Mr Sutcliffe.
CKS are realists however and they have some concerns.
?Business buys peace of mind, and confidentiality trumps environmental concerns nine times out of ten,? states Mr Morgan. ?At the moment it is a wild west out there, with little standardisation amongst operators of deletion options and insurance coverage. The first casualty of any price war on end of life treatment is usually the standards and costs of proper process. Too few customers are translating their data concerns into non-negotiable practice. As in the case of treatment for hazards and toxins, best practice should be the demand, not least cost minimal compliance.?
Mr Morgan adds, ?As an industry we also need to set realistic expectations with our customers. There are known hazards, such as those contained within CRTs, for which there is no economically viable treatment method that will render all the materials safe enough for reuse. Thanks to the increasing influence of the United Nations it is now illegal for these hazards to be handed over to developing countries, even within the EU. The pressure is rightly on within the UK for us to invest in research and treatment options that address our own problems. Buyers of such equipment have ethical responsibilities to contribute to this need.?
The substances which cause most concern environmentally are heavy metals and oxides of: elements such as lead, mercury, cadmium and chromium; and, compounds such as halogenated substances e.g. CFCs, polychlorinated biphenyls (aka PCBs, not to be confused with printed circuit boards), PVC and brominated flame retardants (which can give rise to toxic dioxins when incinerated). Other components of concern are arsenic, asbestos, nickel and even copper, which can act as a catalyst to increase the formation of dioxins during incineration.
Although manufacturers and specialists such as CKS can only take reactive measures to these substances that currently are to be found in IT equipment, there is plenty they can do about them in future.
Mr Morgan adds that ethical manufacturers such as Dell are working towards eradicating the inclusion of dangerous substances in their products.
?Thanks to the RoHS Directive, by the middle of this year it will be illegal to include certain hazards within new products. However, it is good to see certain manufacturers going above and beyond the call of duty. For example, Dell have recently made a corporate commitment to be completely green by 2009,? says the director. ?This commitment has already been translated into reality with the production of a carbon neutral motherboard. It would be good to see business play their part by halting the purchase of older, less energy efficient and more hazardous products when there are cleaner alternatives available, e.g. LCDs in place of CRTs.?
An issue that both CKS executives wish to emphasize is the lack of guidance on businesses? responsibility for their IT equipment and how WEEE should only be viewed only as a starting point and not an answer to all the challenges being thrown up.
?The UK government has a lot to answer for in the transposition delays associated with WEEE,? states Mr Morgan. ?When the WEEE Directive was signed in 2002, it was simply intended as a starting point, one that addressed the most urgent issues [around waste treatment] first, that would then be reviewed and expanded to bring greater structure to waste avoidance. That review is already underway and by 2008 we will have an expanded and updated Directive to deal with. The UK government has allowed the development, discard, development, and disposal of one over-engineered implementation proposal after another. That is waste creation at bureaucratic scale.?
According to Mr Sutcliffe, ?Frustratingly all the debate around the WEEE Directive has hidden the fact that business responsibilities aren?t even a WEEE issue. Indeed, the business user?s Duty of Care responsibilities have been in place since 1991 under Environment Protection Regulations. These responsibilities don?t pass on to producers and manufacturers, business users shouldn?t be waiting for this to happen.?
?Indeed, it is only in the last week that the DTI has started reminding business about these responsibilities,? adds Mr Morgan. ?It?s taken nearly 5 years to remember that we already have a legal framework that addresses the ?missing link? in WEEE. All the DTI now need to do is ensure that their practice guidelines are published and the linkages to Duty of Care made even more obvious. Then there will be no further excuse for assuming the problem is someone else?s.?
These delays will continue to hurt UK industry in other ways.
?In the UK we?ve been engaged in multiple rounds of consultations with the wrong people,? says Mr Morgan, ?whilst other countries have implemented and have moved on to take a leadership role in areas that will next be the focus of attention. In October 2005 the EU stated their intent to invest in pan-European information systems to support compliance reporting and consistency of approach to producer collections.
They also stated clearly their disappointment at the local interpretation and spin put on the WEEE Directive which was hampering the smooth flow of goods and services across the region. Despite this we persist in our attempts to invent a better WEEE for the UK and suffer from none at all. So it should come as no surprise when the UK?s IT industry aren?t strongly positioned when it comes time to tender for these pan-European projects. Just because the UK government has let down its IT industry and the environment doesn?t mean that other countries have done the same.?
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Why the UK WEEE directive is not viable