The Rbrc Program Canada And The Us

As this topic is extensively treated in chapter 5, only a short summary will be given here.

The Rechargeable Battery Recycling Corporation is a not-for-profit corporation funded by rechargeable battery manufacturers and created to implement and maintain Ni-Cd battery collection and recycling programs in the U.S. and in Canada. The RBRC program, Charge Up to Recycle!, has created various recycling plans to collect Ni-Cd batteries, which are then sent to INMETCO (Ellwood City, Pennsylvania) for processing and recycling. At the facility, the nickel and iron are separated from the cadmium and shipped to specialty steel producers for use in stainless steel products. The recovered high-purity cadmium is used to produce new Ni-Cd rechargeable batteries. Within the Charge Up to Recycle! program, three different plans for collecting used Ni-Cd batteries are set up for retailers, communities, and business&public agencies. To reach high recycling levels, widespread public education is carried out. The recycling program is paid for by the rechargeable power industry. To date, virtually all of the major producers and users of Ni-Cd batteries in Canada and the U.S. participate in the program, which also has the support of over 30,000 collection sites, where consumers can drop off their used Ni-Cd batteries for recycling.

V. LESSONS LEARNED & RECOMMENDATIONS FOR ACTION G. Lessons Learned

1. Difficulties in Establishing a Network of Collectors

One hurdle to be cleared in recycling significant numbers of used Ni-Cd batteries is to assure that the batteries are amassed in convenient locations for shipping to a reclamation facility. In every country studied, this collection objective has been the hardest to accomplish. Many other recyclables are collected for their value as commodities. These materials, whether old newspapers, scrap metals or lead acid batteries, have positive economic value and are sought out by entrepreneurs seeking profit. In contrast, spent Ni-Cd batteries are useful as a source of raw materials when processed, but the combined cost of collection, transportation and processing far exceeds their raw material value.

To an extent, this impediment can be overcome by identifying convenient points for consumers to drop off their spent batteries. These can be operated by government, the private sector or both. Unfortunately, however, the initial experience of most used Ni-Cd battery collection programs has been that regulatory constraints greatly impede this effort.

In many countries, because of their constituent cadmium, used Ni-Cd batteries either are now or were considered to be hazardous waste. This designation carries with it substantial burdens for those that handle such material. Generally these entities must meet requirements that were developed to address concerns relating to such industrial wastes as used solvents, acids and the like. They thus require operating and transportation permits, must provide protective safeguards against spillage and loss, must demonstrate financial responsibility to guarantee cleanup of accidents, and so forth.

The operators of those facilities best situated to collect used Ni-Cd batteries have universally balked at voluntarily undertaking the expense, complexity and liability associated with the these obligations. Compelling entities that sell Ni-Cd batteries at retail to take them back for recycling is little better; few welcome this burden, enforcement is difficult, and ultimately, retailers can simply discontinue selling new batteries rather than take on these problems. Since there are some appliances for which there is no alternative to Ni-Cd batteries power, consumers will resort to mail order or other avenues of obtaining the batteries that they need and have no feasible way to recycle them.

2. Need to Assure Transportation to the Recycling Facility at Reasonable Cost

Once used Ni-Cd batteries have reached a collection point, the next step is to move them in bulk to the facility that is to process and recycle them. In many instances it is necessary to consolidate smaller loads before shipment to the recycling facility economically can take place.

Transportation and temporary storage costs represent the largest overhead costs in a recycling program. These costs increase dramatically with the distance between the point of collection and the point of recycling. Furthermore, because there are currently only less than ten facilities capable of environmentally sound recycling of Ni-Cd batteries, these distances can be substantial.

Moreover, when a material is designated as a hazardous waste, it is generally required that a specially permitted and bonded transporter be the only party to undertake the movement of hazardous waste. This is because hazardous waste is presumed to be capable of doing great damage to the environment if spilled and must be cleaned up by specially trained personnel. But the use of a designated hazardous waste transporter increases the cost of moving material in commerce substantially.

At the same time, used Ni-Cd batteries require no different handling than that applicable to the new product. They simply do not present the unique risks that typify hazardous wastes: they are not liquid, semi-liquid or easily dispersible, acidic or corrosive, or otherwise dangerous to touch. If "spilled," they can be easily swept up.

Their potentially hazardous constituents are encapsulated and unavailable to the environment. Those constituents can only be released by the processes (opening and crushing) that occur intentionally.

3. Need to Assure Predictable and Swift Transboundary Movement

Reclamation of metals from used Ni-Cd batteries requires use of complex industrial processes that demand substantial investment. Only less than ten facilities currently operate that can successfully perform this work. All are in OECD member nations, and each is carefully regulated by the governmental authorities of that jurisdiction.

Because there are so few facilities recognized by OECD member states as capable of recycling Ni-Cd batteries, the necessity of moving them across international borders is evident. Where a nation has no such facility, the options for dealing with spent Ni-Cd batteries within its jurisdiction are limited to either exporting them for proper recycling or disposing of them (landfilling or incinerating) domestically. The former is environmentally preferable.

Transboundary shipping requirements (i.e., notice and consent paperwork) are a potential impediment to such movement, however, if they are unnecessarily burdensome and time consuming. This is important both from the perspective of encouraging collection and shipment for recycling, and in order to assure the economic success of reclamation activities. The facilities that process and recycle Ni-Cd batteries require a degree of certainty about the availability and time of arrival of their feedstock. Delay or uncertainty of supply adds to costs and undermines the recycling process.

H. Recommendations

1. Overly Stringent National Controls Should Be Modified

The burdens associated with collection, storage, transport and processing of spent Ni-Cd batteries and Ni-Cd battery manufacturing scrap are extremely important in determining whether or not a collection program will be viable. Economic penalties and administrative complexities associated with collection and transportation of materials designated as "hazardous" may make the cost of collection impossible to bear.

As noted above, where the administrative and/or economic penalties are high, retailers and others with desirable candidate collection locations are dissuaded from participating in the collection program. These candidates rarely are dependent on Ni-Cd battery sales for a substantial share of their profits. Thus, even if a government mandate requires that all locations selling Ni-Cd batteries participate in a collection and recycling program, they cannot be expected to incur unreasonable costs and obligations and may easily elect to discontinue selling new Ni-Cd batteries. Neither the consumer nor the environment benefits from this. Consumers are likely to seek replacement batteries outside the jurisdiction of the government applying the mandate and have no feasible place to recycle them.

Comparisons in the U.S. show a shipping cost increase of a factor of 2 to 10 for the same used batteries, depending on whether they are characterized as hazardous or non-hazardous. How steep the increase is dependent upon the shipment size and whether it is a dedicated or backhaul trip.

The regulatory provisions that are most responsible for this substantial cost increase are those requiring the batteries to be accompanied by a hazardous waste manifest and transported by licensed hazardous waste haulers. More affordable common carriers transport new Ni-Cd batteries, which are substantially identical to the used product. There thus appears to be no environmental reason to preclude them from similarly transporting properly packaged used Ni-Cd batteries that are accompanied by a standard bill of lading that identifies the shipment contents and the final recycling facility destination. Such documents are used successfully to move material in commerce where the primary concern is, as it is here, to make sure the goods reach the proper destination.

For just these reasons, several OECD member nations (such as Canada, Sweden and the U.S.) have created exemptions from otherwise applicable hazardous waste regulatory requirements to encourage recycling. In these nations, extensive industry-led efforts are underway to facilitate easy collection and transportation.

The OECD would exhibit considerable environmental leadership bv producing guidance materials that recognize the value of a uniform and efficient system to channel Ni-Cd batteries to pre-authorized recovery operations. This guidance would recommend the relaxation of hazardous waste requirements on the collection and transportation of used Ni-Cd batteries to those collection facilities recognized by the OECD member nations to he capable of environmentally sound reclamation of their constituent materials. National governments with environmentally sound and compliant facilities could be requested to certify their status to OECD.

2. National Controls Should Be Harmonized

Economies of scale, and the concomitant limited number of recovery facilities, dictate the need for cross border movement of spent Ni-Cd batteries for recycling. Unfortunately, a lack of harmony between the regulatory regimes in the importing and exporting jurisdictions can result in a substantial impediment. Within the OECD there are many different such regimes. Where OECD member states differ significantly in their approach to the regulation of spent Ni-Cd battery collection, transportation and recycling, movements necessarily will have to meet the most stringent - and most cost prohibitive - regime.

Again, action by the OECD to urge to the member nations to adopt uniform provisions to encourage Ni-Cd battery collection, and avoid characterization of the batteries as fully regulated hazardous waste would assist in solving this problem.

3. Unnecessarily Burdensome Transboundary Requirements Should Be

Eliminated

Amber list controls currently apply to all intra-OECD shipments of Ni-Cd batteries. Such controls may make sense for batteries shipped between nations for disposal in a landfill, because the nation of import necessarily requires an opportunity to verify that they are destined for a facility that has the capability to deal with them in an environmentally sound manner. For Ni-Cd batteries collected in intra-OECD commerce for recycling, however, these controls can impede efficient movement and result in unnecessary storage time and administrative cost. Indeed, time delays and administrative burdens mount up incrementally when one is dealing with the recycling of a used material that has little or no economic value until it has been reclaimed. At some point, these additive burdens become sufficient to render recycling cost prohibitive.

Many of these amber list controls are not necessary. For example, in the context of Ni-Cd battery recycling, used Ni-Cd batteries are no more hazardous to transport than new ones. Their potential hazard lies in their long term disposal in locations from which where the constituent metals theoretically might leach, or from incineration. Furthermore, as discussed above, there are only less than ten facilities in the world (all within the OECD) which are capable of recycling Ni-Cd batteries. If the member nations in which these facilities are located are satisfied that their operations are being operated in an environmentally responsible manner, advance notice of shipments serves no purpose.

Thus, the only potential benefit of the amber scheme is to prevent shipment to other locations. The Working Group on Waste Management Policy could take a significant step in facilitating Ni-Cd battery recycling by recommending that transboundarv shipments between OECD nations to these locations, or others recognized by national governments as acceptable, should be allowed to proceed under green list or significantly scaled back amber list controls. This reduction in control would only apply to shipments destined for facilities that have been identified by their home country's environmental authority as an environmentally sound facility, operating in full compliance with domestic environmental law and regulations.

Shipments to these facilities under green list controls would represent no threat to human health or the environment. To the contrary, using green list controls would greatly facilitate an efficient system of removing these batteries from the environment and encourage businesses in OECD member nations to funnel batteries collected under national programs to the safest and best documented recoveiy operations.

The environmental benefits of such a policy action are clear. To the extent that regulatory burdens are eased, including those related to intra-OECD transboundary movements, more Ni-Cd batteries may become available for recycling. This increase in the availability of feedstock may well encourage the establishment of new, technologically advanced recovery facilities within the OECD, or the expansion and technological upgrading of existing facilities. This increased recycling capacity also would generate more recoverable material for use in place of virgin materials and decrease overall shipping distances.

4. Government / Industry Cooperation Should Be Facilitated

It is clear, in light of the complexity of portable electric product manufacture and distribution channels and the rate of technological change, that any used Ni-Cd battery collection scheme must be able to accommodate changes in industry structure and product mix. The nimbleness thus required is readily supplied by market mechanisms, and difficult - if not impossible - for public agencies to match.

Furthermore, the economics of material recovery, the cultural attitudes of the population being asked to recycle, the logistics of material collection, and the efficiency of various transportation options can vary considerably, even within nations. Attracting and keeping cooperative program participants is greatly enhanced if potential participants are given the opportunity to shape the program around cultural and economic realities of the marketplace in which the program is to function.

All of these factors contribute to making voluntary programs, organized and implemented by product suppliers, the most attractive mechanism to obtain maximum rates of used Ni-Cd battery collection and recycling. Among other things, participants who voluntarily participate in programs are far more active and enthusiastic. They have a very real investment in the success of the program and will be more likely to suggest improvements designed to increase collection and recycling rates.

Thus, governmental policies should be directed to encouraging voluntary arrangements. The OECD should act as facilitator for organizing such private sector and government interaction.

Funding is a particularly sensitive issue. All of the world's facilities that reclaim materials from Ni-Cd batteries at present are being paid to do so. That is, because of low metal prices, reclamation - even where the reclaimer has no responsibility for collection - is not currently profitable through the recovery of the metals alone. Thus, a funding mechanism for Ni-Cd battery collection and recycling programs must be established before a program can be realistically implemented.

The appropriate funding mechanisms will vary with national policies and historical factors. In some countries, there is historical precedent for the imposition of fees on retailers, and acceptance by consumers of this additional tax. But this is not always fair or reasonable. Fees must be proportional to the actual costs of collection, transportation and reclamation if they are to be accepted by the consumer and not distort the market. Similarly, these fees must be segregated from general governmental revenue in order to allow accurate accounting of actual costs of recycling.

In Sweden, for example, fees paid on Ni-Cd battery purchases in Sweden far exceed the costs of a collection and recycling system. Indeed, they appear to have been imposed by the government as a punitive "tax" in an attempt to force Ni-Cd batteries out of the market in favor of batteries utilizing other chemistries. In this age of internet commerce and rapid mail order delivery, consumers that are given a significant monetary incentive to do so can just as easily buy their batteries outside such a program and avoid paying the punitive fee.

Fees also should be collected at the time the new Ni-Cd battery or appliance is purchased. To do otherwise, that is to collect it at the time of consumer drop-off, creates a disincentive to recycling.

Yet, having the private sector implement these programs also faces difficulties. In the U.S. and Canada, for example, competition laws limit joint voluntary action to impose anything like an advance disposal fee. The RBRC solution to this in Canada and U.S. was to set up a voluntary funding scheme that is paid for entirely by the rechargeable power industry. Each participating battery manufacturer or battery user pays a licensing fee that is proportional to the total combined weight of Ni-Cd cells that the company markets in the U.S. and Canada. Licensees may display the RBRC seal on

Ni-Cd batteries, the devices powered by the batteries, their packaging and the instruction manuals for the devices. While this arrangement also requires a substantial investment in administrative support, the fact that business interests are in direct control of the administrative process maximizes its efficiency.

While the attractions of voluntary systems are thus legion, they have one disadvantage: they rely on the good faith of all market participants to be truly equitable and fair. The problem of free-riders (i.e., battery and product manufacturers who do not support or participate in the program but who benefit from it) has been serious enough to generate significant concern among program participants and regulators. Focusing government attention on this segment of the marketplace, by requiring that companies support some sort of a voluntary system, may be a solution. Another means of minimizing the free-rider problem will be to promote participation in the recycling program as a product attribute. Through aggressive advertising campaigns, consumers should be alerted to look for Ni-Cd recycling program logos on batteries and products and to support collection efforts by buying paying participants' products.

The overall program success thus far in North America is a function of sensible regulatory solutions that were developed and agreed upon mutually by both the rechargeable power industry and regulators. These entities, that can so often be at odds, put aside differences and cooperated to achieve an important environmental objective. The program has received considerable publicity and widespread public acceptance and the annual tonnage of batteries recycled has continued to grow.

Appendix

OECD's Member States

European Union: Austria, Belgium, Denmark, Finland, France, Germany, Greece,

Ireland, Italy, Luxembourg, Netherlands, Portugal, Spain, Sweden, United Kingdom North America: Canada, Mexico, United States Pacific Rim: Australia, Japan, New Zealand, South Korea Others: Czech Republic, Hungary, Iceland, Norway, Poland, Switzerland, Turkey

Used Battery Collection and Recycling G. Pistoia, J.-P. Wiaux and S.P. Wolsky (Editors) ©2001 Elsevier Science B.V. All rights reserved.

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