For years, I have been sitting in meetings with DTSC, attending their workshops, reading their emails and have always felt like something was missing: logic and purpose. DTSC’s purpose is to protect California’s people and environment from harmful effects of toxic substances, but they get so bogged down in bureaucracy and regulations that what they do seems to lack logic.
Stakeholder meetings in which I have participated have felt like they were being set up to prevent progress, rather than to make progress. Dealing with state agencies and conflicting stakeholders isn’t new to me. I have been a part of numerous stakeholder meetings. Typically the entity in charge of convening the stakeholder meeting will set up parameters for stakeholders to work from. These parameters serve as a point of reference to know what the goal is and what the organizing entity believes can be realistically accomplished.
I remember asking for such parameters from former DTSC director, Maureen Gorsen, after she stated that we (stakeholders) should ask for whatever we wanted with the Green Chemistry Regs (now called the Safer Consumer Products regulations). I said we could ask for the moon but it would not be realistic, her response was – go head and ask for the moon. How’s that for constructive guidance? A lot of people travelled from throughout California to participate in this stakeholder meeting and I could not help but feel like the lack of direction was wasting everyone’s time.
I was disgusted that the head of a state agency, tasked with protecting California’s communities and environment, would have such a flippant response. The seriousness of DTSC’s task is in its name – toxic substances.
SVTC has seen a lack of enforcement by DTSC for the last 15 years. For many years DTSC allowed lead laden televisions and other devices to illegally go in California landfills.
But nothing could prepare me for what I would read in Golden Wasteland:
DTSC has allowed a company that “makes specialty chemicals for industry from the hazardous waste it accepts from the computer, chemical and aerospace industries” to operate on an expired permit for 16 years. This is a facility that DTSC ordered to fix problems in 1999, 2000, 2003, 2007 and 2010.
They also may be responsible for the deaths of members of the community who lived near the chemical manufacturer. The community complained and asked DTSC to investigate.
Now, the facility wants to expand and according to the report, DTSC has already drafted a permit to approve it. Where is the logic behind that? How does that fulfill the mission of DTSC to protect communities or the environment?
If I had community members contacting me about families who have died and are dying from cancer in one given area, I would do everything in my power to get answers and if it was in my power, stop it from continuing.
And perhaps that is why the author of Golden Wasteland writes with such urgency, not a vendetta against DTSC, but with the understanding that lives are on the line.
Now clearly, not everything is the fault of DTSC. It seems that the whole system under Cal EPA is flawed and laws that are being passed are vague and possibly not giving them the teeth they need.
It is only fair to share that DTSC did issue a response to the report:
But unfortunately, I found it lacking in real answers to the issues that were addressed in the report.
We know that the current Director, Debbie Rafael, inherited a lot of these problems. But I do I wish she would have blown the whistle on what was happening at DTSC when she got there. Then she could have taken control over the situation and posted an explicit plan on how she intended to fix the problems when she took over (like making sure companies aren’t running off expired permits) and restore public confidence in the agency.
The impacted communities deserve better.
SVTC’s work has been hindered as DTSC allows companies to hide behind trade secrets at the expense of public health.
But all of this pales in comparison when you look at people in communities who are dying under DTSC authority. This must change.
We are hopeful that Senator de Leon is successful in his call for an investigation of DTSC: http://sd22.senate.ca.gov/news/2013-02-21-release-alarming-mismanagement-hazardous-waste-lax-enforcement-allegations-senators-.
And we are hopeful that legislation like AB 1329 which will reduce racial and economic disparities in siting hazardous waste facilities passes:
We hope that DTSC doesn’t get so caught up in wordsmithing responses to criticisms and just starts to take action to protect ALL Californians from toxic materials.
If you’ve been following SVTC’s work, you know that hazardous waste from solar is news, but discussions about the solar industry’s environmental impacts are not new.
Since the 2009 launch of our solar campaign and Solar Scorecard, SVTC has warned that solar manufacturing technologies are similar to those of the semiconductor industry and that the solar industry risks having the same damaging life-cycle impacts.
The difference of course is, that this industry is supposed to be “clean and green,” and its purpose is to create energy without hurting the environment.
The solar industry will continue to come under scrutiny and will be accused of hiding its “dirtier side” until it gets serious about collecting environmental information, sharing it with the public, and setting goals to get rid of toxics.
Fortunately, the solar industry is still just getting started and can shake the legacy of hazardous waste—but it shouldn’t wait too much longer. SVTC will be sending out our 2013 solar survey soon…a perfect opportunity for companies to take action and not waste any more time.]]>
The Winchester Mansion was built in 1884 by Sarah Winchester, the gun-manufacturer heiress. She believed she was being haunted by victims killed by Winchester rifles and she spent the latter part of her life building rooms and doors onto her mansion in order to appease these spirits. She added 160 rooms and 950 doors, most of which lead to dead-ends.
Similarly, DTSC continues to add to the State’s complex maze of hazardous waste regulation without a blueprint for environmental sustainability.
For example, The DTSC Proposed Standards for Management of Waste Solar Panel recommends solar modules to be regulated under the same universal waste rule as the State’s e-waste.
This is a bad idea. The State e-waste recycling program continues to allow California waste to be dumped overseas to poor countries that do not have infrastructure to recycle the waste. We have seen this type of dumping devastate entire villages and impact human health.
DTSC’s proposal for solar waste recycling does not include any incentive for the recyclers or solar companies to build recycling infrastructure in California, so we can expect our solar waste to suffer the same fate as e-waste.
That means California will lose recycling jobs and the State’s toxic solar waste will also be dumped in poor countries or shipped to out of-state landfills.
The proposed recycling program will also lead to consumer confusion. Solar customers will have no idea what to do with their panels at the end of the panel’s life.
DTSC’s proposed solar recycling program only includes solar panels that are classified as hazardous waste. And the proposal does not require a label to let customers know that the panel is hazardous waste and how the solar panel should be recycled.
SVTC wrote a letter expressing our concerns about these regulations when they were first introduced in 2010 . After two years of internal review, DTSC has not come up with any new ideas. In 2012 they released almost exactly the same proposal. Unfortunately,DTSC has wasted a lot of time and opportunity on this poorly thought-out proposal.
SVTC resubmitted our 2010 comments strongly stating our concern that any new solar recycling regulations should require manufacturers to take responsibility for recycling their own products. We also recommended that DTSC conduct a third party review of regulations three years after adoption
The solar technology is rapidly changing which means that the industry’s recycling needs will also change. Yet the DTSC proposal does not even include a provision to evaluate the regulations to see if the recycling program is working.
DTSC is continuing to construct a daunting solar panel recycling system that is full of regulatory twist and turns that lead to a dead-end.
DTSC is building its own version of the Winchester Mansion.]]>
Apple products are poisoning workers who make them. This is well known, thanks to a long campaign by activists. Recently, Apple accepted this too and promised to remedy this.
That’s good news. Ensuring worker safety is an important step towards cleaner electronics. But back here in India, it is workers at the other end of a product’s life cycle that we should worry about-at the end of disposal. Informal waste collectors and dismantlers handle over 90% of India’s e-waste. Yet, their work is not clean. They work in the heat, the monsoon and in the icy cold winter, under appalling conditions. Experience tells us that even when they become formal, by forming associations or companies, their safety and health may still be compromised, unless producers themselves shift to clean production.
Let me explain. When you form a company or an association, you can apply for permits to be an e-waste collector. When you get this permit, which can take up to a year and many indirect costs, you can go out and collect electronic waste. What then?
For most informal sector actors, collection and selling e-waste to other dismantlers is still the best option. Dismantling requires more investment in training, skilled workers already familiar with dismantling, additional equipment and tools etc. This is difficult to procure even if you are organized. What is even harder is that many bigger cities are unwilling to give permits to set up more dismantling units, because they see dismantling electronics as a highly toxic enterprise because of what’s inside the old computers, phones, T.Vs and other electronics we trash. Delhi and its neighbouring city, NOIDA, are two cases in point. This trend is likely to expand to other bigger cities. Unfortunately, they have a point-electronics do have toxics inside them. And while dismantling is not a toxic process, and does not burn or extract any metals, it can still lead to some toxic releases. If monitors break, for example. Or when they use blow torches, operating at high temperatures, to remove smaller components from mother boards.
This means that workers from the informal sector cannot value add and earn the most money from the e-waste they collect because the manufacturers have pumped them up with dangerous chemicals and this has the authorities very wary about dismantling except by very capital intensive plants. This is worrying for two reasons. First, that poor-and inconsiderate- design reduces the legal earning for such workers. Second, that this acts as a disincentive for workers who are currently dismantling to actually formalize, because they will have to change their line of business to collection, where their core skills will be unused. They may even experience a reduction in incomes. Such a disincentive is bad for them and bad for the environment. If they continue to dismantle, they bear the brunt of the toxics in electronics. If they expand their business, as many of them hope to do, collection will only be a means of vertical integration and to secure their dismantling businesses. It will be peripheral. For most, real expansion means adding value and increasing incomes from opportunities in extraction-even if it is illegal. Again, they will end up exposing themselves and other workers to dioxins, lead and acid fumes.
The new rules on e-waste in India, the E-Waste (Management and Handling) Rules, 2011, mandate toxics reduction. Despite the occasional criticism of these, they are a first step to making electronic waste handling fair on the workers. More important is that producers of electronics clean up the insides of their products. Apple has taken a step, although it has a long way to go. The others must take their first step soon. It’s time to stop letting the workers at either end of the product chain to take in the poisons from our hyper-connected, comfortable life-styles.]]>
San Francisco, CA – May 10, 2012 – The Silicon Valley Toxics Coalition (SVTC) today announced the release of its 2012 Solar Scorecard that ranks manufacturers of solar photovoltaic (PV) modules according to a range of environmental, sustainability, and social justice factors.
“In this competitive solar market, top-tier panel makers are distinguishing themselves from environmental laggards by responding to SVTC’s survey and posting environmental data on their websites,” said Sheila Davis, Executive Director of SVTC.
The highest scores this year went to China’s Trina (94), the USA’s SunPower (93), and Germany’s SolarWorld (91).
The 2012 Solar Scorecard represents 51.1% of the PV market share.
Key findings from the Scorecard include:
• 13 of the 14 companies surveyed said they would publicly support Extended Producer Responsibility (taking back and recycling their products), up from 6 of 14 companies in 2010.
• 100% of the companies that responded reported they do not use prison labor and eight of the companies have written policies forbidding this practice.
Companies were scored in the following categories: Extended Producer Responsibility (EPR); workers’ rights, health, and safety; disclosure of chemical use and emissions; supply chain monitoring; sustainability practices; and use of life cycle analysis.
The 2012 survey took a deeper look at corporate transparency and the type of information being provided to the public.
• 4 companies post hazardous waste reduction targets on their websites or annual/sustainability reports.
• 8 of 14 PV module manufacturers post greenhouse gas emission information on their websites or annual/sustainability reports.
“Photovoltaic manufacturers are increasingly reporting health, safety, and sustainability metrics on their websites and within annual reports. However, too many solar manufacturers are still unwilling to share their emissions information,” said SVTC Research Scientist Dustin Mulvaney, who contributed to the Scorecard survey. “Part of a solar manufacturer’s value proposition to its customers is its environmental credentials. Those who are transparent and make a genuine investment will be rewarded with consumer confidence.”
“Transparency is crucial to all green businesses,” said Ms. Davis, “This year companies that did not respond were scored based on the information on their websites. In SVTC’s third year of releasing the Scorecard, we’ve come to realize that companies that do not respond seem to have little positive news to report.”
The investment companies that support SVTC’s Solar Scorecard include Boston Common Asset Management, PaxWorld Management LLC, and Walden Asset Management.
“Boston Common Asset Management is very pleased to have supported the Solar Scorecard for a third year,” said Steven Heim, Managing Director. “The results show the importance of social and environmental issues and how they are increasingly becoming recognized by the industry. We are encouraged by new companies sharing their practices with the public and investors via SVTC’s Solar Scorecard.”
For more information, go to www.solarscorecard.com.
About Silicon Valley Toxics Coalition
Silicon Valley Toxics Coalition is a non-profit organization engaged in research, advocacy, and grassroots organizing to promote human health and environmental justice in response to the rapid growth of the high-tech industry. For more information, go to www.svtc.org.]]>
Despite economic disruptions and dramatic price drops in solar panels, many solar companies remain committed to the environmental principles outlined by SVTC. SolarWorld, First Solar, Solon, Sovello, and Yingli have responded to the Solar Scorecard since 2010 and we would like to thank them for their leadership.
Although the overall number of companies responding to the Solar Scorecard survey has remained steady at about 14, the total market share of the participating companies has doubled from 26% in 2010 to 51% in 2012.
We think that the increase in participation from larger companies is a good sign for the solar industry. SunPower (4.4% market share), REC (3.3% market share), and Trina (8.1% market share) have responded to the Solar Scorecard survey since 2011. In 2012 we welcomed the participation of Suntech (10.4 % market share). Companies that are actively implementing environmental programs want to differentiate themselves from the laggards who are actively cutting cost by sacrificing environmental protections.
Solar companies are considered “green” businesses and therefore should enthusiastically report their environmental practices.
We have learned that start-ups and smaller companies, typically strapped for time and resources to commit to sustainability programs, do not score as high as the larger companies. We are very encouraged and impressed by Motech, Solon, SoloPower, and Sovello’s willingness to continue to respond to the survey and demonstrate their commitment to environmental issues.
As the industry continues to consolidate, less than 15 companies sell 90% of the PV modules on the market. It would be a travesty for the solar companies with the cheapest modules, yet most egregious environmental practices, to be deemed industry winners.
Any company that refers to itself as a “green” business should make its environmental record available to the public. Thus, SVTC turned to the information publicly available on the websites of companies who did not respond to the Solar Scorecard to score their environmental practices. LDK and Jinko Solar earned zero points. Hanwha SolarOne, Schott, and Canadian Solar earned two points each. In SVTC’s third year of releasing the Scorecard, we’ve come to realize that companies who respond to the Scorecard survey are industry leaders who are driving environmental changes. Conversely, companies that do not respond to our survey and do not post information on their websites probably have very little positive news to report.
We hope customers will use the Solar Scorecard to make purchasing decisions that support companies with the best environmental records.
Here is a summary of the progress we’ve seen among the industry leaders over the last 3 years:
• 92% companies responding to the survey said they would publicly support extended producer responsibility, up from 57% in 2010.
• 100% of the companies reported they do not use prison labor and eight of the companies have written policies forbidden this practice. This is up from the 64 % of the companies that reported they would not use prison labor in 2010.
• 86% of companies that respond to survey have a code of conduct in with their suppliers that is in alignment with Social Accountability International 8000 standard, which ensures that working conditions are free from child or forced labor, provide a safe and healthy living environment, and comply with local laws for collective bargaining, working hours, discrimination, and compensation. In 2010 only 42 percent of the companies required their direct suppliers to follow a worker code of conduct or other set of publicly available standards]]>
We’ve created a visual website to help illustrate some of these potential risks that we are warning about.
When you visit SVTC’s Solar Lifecycle website, you will be guided through each stage of a solar panel’s life and the associated risks – from the mining of materials used to create a solar panel to the eventual disposal of a panel at the end of its life. Today the website illustrates the two most common types of solar panels – polysilicon and cadmium telluride.
The making of a solar panel is pretty complicated. We’ve taken all of the scientific information and drilled down to the essential information to help you understand the impacts on the surrounding environment (soil, air, water) and workers and nearby communities.
For 30 years SVTC has watched the electronics industry stumble from one environmental and health crisis to the next and we’ve successfully advocated for a cleaner and safer industry since the first toxic chemical spills in the early 1980s. Unfortunately, many of the same technologies and processes are used to make electronics and solar panels – and SVTC certainly does not want to see solar make some of the same fatal mistakes as the electronics industry.
We are optimistic that we can build a truly clean energy supply that is safe and sustainable for our planet and all of its inhabitants. But we need to think critically and learn from past mistakes to help today’s vital solar energy industry expand in a sustainable way.
Act today. Arm yourself with knowledge. Visit SVTC’s newly launched Solar Lifecycle website.]]>
The complaint filed by seven manufacturers has divided the US solar industry and resulted in another group, calling itself the Coalition for Affordable Solar Energy (CASE), to form in response to CASM’s complaint. CASE claims that cheap Chinese panels make solar energy affordable in the US and creates rooftop installation and sales jobs.
The ITC may find US solar companies are in fact being injured by Chinese violations of free trade agreements. However, free trade isn’t the biggest problem facing solar manufacturing in the US. The biggest problem is that the US government hasn’t made a significant financial commitment to renewable energy or developed a long term strategy to make solar economically and environmentally sustainable.
A forward-thinking US policy committed to the economic and environmental sustainability of the solar industry would find ways to create business opportunities throughout the solar panels’ lifecycle, which would mean creating policies that support safe domestic mining, manufacturing, installation and recycling of solar panels.
The US is projected to be the largest solar market by 2012. It would seem that US policymakers across the political spectrum would get behind building capacity for US-based solar manufacturing. A compelling case can be made to support solar manufacturing for the purpose of addressing climate change, creating jobs, promoting energy independence and growing the economy.
In addition to being the largest solar customer, the US will also likely be one of the largest solar panel waste generators in the world. A commitment to long-term sustainability in the solar industry would include investing in recycling systems to handle the millions of tons of panels and create new jobs in recycling related industries when the panels are decommissioned.
Instead, policymakers are spending time obsessing over Solyndra. It’s important to determine what went wrong (if anything) with the Department of Energy (DOE) loan process – or if there is political favoritism in the DOE program. However, the congressional debate about Solyndra and the subsequent media coverage has supplanted all substantive discussion about the US long-term strategy for solar.
It’s hard to watch the US solar industry take such a beating. However, it’s not just cheap Chinese panels that are creating the problem. Some of the most serious blows to the industry are coming from our federal government.]]>