The Device Renewal Forum (http://DeviceRenewalForum.org) is an entity, that among many lofty goals, has been created to encourage the recycling and renewing of wireless devices, ensure only high-quality renewed devices enter the marketplace, and will act as a “certification authority” authorizing the application of certification (aka, a brand) labels on devices (and their packaging) that pass the test and certification process. The founding members of the Device Renewal Forum include eRecyclingCorps, Brightstar Corp, CDG, Sprint Nextel, and ModusLink Global Solutions. In its most basic sense, these cell phone industry folks are selling a “green” badge of honor (aka, a brand) if you meet their UNDEFINED criteria (undefined on their own website for about five months). Oh, and they charge you for it.  
 
 
 
Please Google the word “greenwashing.” Read the Wikipedia definition. “Greenwashing (a compound word modeled on "whitewash"), a form of spin in which green PR or green marketing is deceptively used to promote the perception that an organization's aims and policies are environmentally friendly. Whether it is to increase profits or gain political support, greenwashing may be used to manipulate popular opinion to support otherwise questionable aims.” In response, the Federal Trade Commission says “[In order to] avoid consumer deception, the advertiser should be able to substantiate [its claims].”  
 
 
 
So here we have the Device Renewal Forum (DRF) meeting early in 2012 in an exotic European locale to discuss a recycling problem that they will endeavor to solve. What qualifies the DRF to create a series of standards that can be applied to refurbished and recycled cell phones and other electronics? The answer: worldwide regulatory experience and the practice of quality engineering and refurbishing standards. Well, okay, then; DRF has the experience and the know-how. I guess the DRF just hasn’t had the time to delineate the elements necessary to obtain their “green” badge of honor. It’s only been five months since they hatched this brainstorm. Give it time.  
 
 
 
But do we really need Device Renewal Forum (DRF)?  
 
 
 
Let it be known that cell phone, computer and television manufacturers must abide by the Restriction of Hazardous Substances Directive (RoHS). This directive was adopted in February 2003 by the European Union. It took effect on 1 July 2006, and is required to be enforced and become law in each member state. This directive restricts the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment. It is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC which sets collection, recycling and recovery targets for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic e-waste. With RoHS, the European Union forced all electronic manufactures (cell phones, computers, televisions, etc.) to stop using materials that will harm the environment when they end up in landfills. RoHS is a powerful “front-end” solution to electronic waste. The rest of the world has reaped the benefits because if manufacturers do not abide by the rules, then they cannot sell. WEEE is strong in Europe, but not on this side of the pond because waste and recycling is easy to regulate from Congress, but difficult to enforce on the street. Even in a strong economy would we ever have “trash police” checking what we dump? Perhaps the giant corporations do have regulators crawling through their dumpsters, but what about smaller repair factories or storefront retailers?  
 
 
 
There are lots of “tail-end” recycling directives in place. For example, Brightstar, one of the Device Renewal Forum founders, is headquartered in Miami-Dade County, Florida and provides logistical services and supply chain management within the wireless telecommunications industry. A local law, Chapter 15, Section 2.3 of the Code of Miami-Dade, requires businesses to recycle three items. States like California mandate commercial recycling in order to be able to conduct business; see California Assembly Bill 32 and 341.  
 
 
 
The DRF wants to “encourage the recycling and renewing of wireless devices.” Does this mean they will push for what the government already mandates they should already be doing? None of these “front-end” and “tail-end” recycling directives materialized in 2012. What took the Device Renewal Forum founders so long to jump on the bandwagon?  
 
 
 
The DRF wants to “ensure only high-quality renewed devices enter the marketplace.” Considering none of the founders are manufacturers (only refurbishers and re-sellers), does this mean they will abide by RoHS and use environmentally-safe materials? Wait, what were they using before the DRF was formed?  
 
 
 
The DRF founders are on the right path. Somewhere on their website they recognize that securing ISO 14001 certification is the best starting point for a company to be environmentally safe. Obtaining ISO 14001 certification means the company has a grip on how to “(a) minimize how their operations (processes, etc.) negatively affect the environment (i.e. cause adverse changes to air, water, or land); (b) comply with applicable laws, regulations, and other environmentally oriented requirements; and (c) continually improve” (a) and (b).  
 
 
 
Therefore, given the RoHS, WEEE, and ISO 14001, does anyone really need DRF certification? Should a company invest in pursuing DRF’s good graces or obtain ISO? Wait, don’t answer that. There is MUCH more to being green. Companies can also pursue upgrading or moving to a building with Leadership in Energy and Environmental Design (LEED) certification; that is, the building is designed, constructed, and operated in a way that preserves the environment. Also, companies can do their best to abide by the regulations established in the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986, directives created to help communities plan for emergencies involving hazardous substances. Quick accident intervention can mean less hazardous materials in our drinking water.  
 
 
 
What about participation in things related to environmental safety? Not recycling, but instead processes that help preserve the environment and our communities. For example, as required by the EPCRA of 1986, have all US-based DRF properties submitted timely and accurate annual Tier II Reports to the Environmental Protection Agency? The reports are due every March. Founding DRF member Brightstar Corp is primarily a cell phone supplier and logistics company, but there are chemicals on the property (diesel fuel, battery acid, chemical cleaners). Has Brightstar Corp ever experienced a chemical spill or a close call? OSHA says the community has the Right-To-Know. Was anyone told? The neighboring daycare a quarter mile away? The media? Can Brightstar’s old Tier II Reports be accessed? A solid history of Tier II Reports would certainly convince me that Brightstar is green and cares about its own community.  
 
 
 
Being “green” goes beyond recycling. Protecting the community can be considered a “green” endeavor. Any company involved in the manufacturing, refurbishing, and transportation of cell phones has the potential to hurt the environment. That is, lithium-Ion batteries in cell phones are considered to be hazardous materials. The transportation of hazardous materials is also something that, like recycling, is important to do correctly for the sake of the environment and innocent people. The International Air Transport Association www.IATA.org) is a global trade organization responsible for, among many things, regulating the shipping of hazardous materials, such as cell phone batteries. Companies shipping cell phone batteries must use drop-test certified boxes, special packaging to prevent battery-to-battery contact during transport, contain information in case of emergency, and amongst other things, as per 49 CFR § 172.604, list a twenty-four hour emergency contact number. Although the shipper may not be the manufacturer of the battery, being able to reach the shipper to provide disposition instructions or other assistance is required. Technical information is obtained from the Material Safety Data Sheet (MSDS). Shippers use companies such as CHEMTREC www.chemtrec.com) as a resource and solutions provider for hazardous materials and dangerous goods response. Using CHEMTREC or other HAZ-MAT information provider requires registering with the provider, supplying the provider with MSDS data on items the shipper transports, and paying an annual fee. Companies that use the CHEMTREC contact number on their boxes without legitimate registration are in violation of federal law.  
 
 
 
Therefore, given the standards of LEED, EPCRA, and the IATA, are the US-based DRF properties complying with those mandates and doing their best to reduce waste and protect the environment?  
 
 
 
Do any of the DRF founders employ a full-time Industrial Hygienist on EACH of their properties to direct “green” efforts, capture the effectiveness of benevolent recycling endeavors on charts and graphs, spearhead spill prevention activities onsite and in the community, etc? Is there any documentation available on DRF founder websites for consumers, citizens, and neighbors like an ENERGY AND MATERIALS USAGE REPORT that delineates, for example, the type of refrigerant is being used in DRF buildings? Or perhaps an itemized list of the amount of paper and cardboard purchased every year? Any corporate sponsored car-pooling programs? How about the amount of RoHS-compliant materials utilized to repair or refurbish cell phones?  
 
 
 
The Device Renewal Forum founders want to become the green pantheon of the cell phone secondary market industry. Ideally, a good start would be to make criteria for membership and certification known. And they need to be transparent in regards to their other environmentally-friendly activities and endeavors such as to usage of RoHS-approved repair materials, number of properties with ISO 14001 certification, recycling efforts as per local-state-federal mandates, LEED efforts, EPCRA reporting, and conforming to IATA regulations.  
 
 
 
The “greener” the DRF becomes, the safer we are…. because if the DRF preserves the environment then the DRF is not hurting us. Do yourselves a favor and hire an Industrial Hygienist for each property. Then we consumers will know DRF is REALLY striving to do the right thing. Here are some related Industrial Hygienist functions that will help the DRF founders:  
 
• Hearing Conservation Programs 
 
• Sick Building Syndrome Evaluations 
 
• Radiation Level Testing  
 
• Ventilation System Testing  
 
• Medical Monitoring Program Development 
 
• Occupational Illness Investigations 
 
• Microbial Testing - Air/Water/Surface  
 
• Safe Work Practices Evaluation  
 
• Bloodborne Pathogen/Infection Control Procedures  
 
• Heat Stress Evaluations 
 
• Noise Surveys  
 
• Asbestos Inspections and Management Plans 
 
• Lead Inspections and Risk Assessment 
 
• Smoke Odor Evaluation 
 
• Chemical Release Monitoring 
 
• Ergonomic Evaluations 
 
• Transient Odor Problems 
 
• Epidemiological Evaluations 
 
• Cancer Cluster Studies 
 
 
 

Hi Jorge – thanks for the detailed post. Your comments are well made and I certainly support your argument that DRF involvement in itself does not replace the need for a comprehensive strategy and approach to environmental stewardship. I do not believe that the DRF members see this as a single ‘green’ initiative through which they can earn their sustainability credentials. When it comes to adopting more sustainable behaviour it is more about managing multiple initiatives within an overall framework rather than just focusing on one area such as recycling, or waste reduction or industrial hygiene. 
 
 
 
ModusLink is proud to be one of the founding members of the DRF. We are on our own sustainability journey and know that we have a lot still to achieve to meet even our own goals in this area. We see huge potential in our own business and in the work that we do for our clients to improve. We do not claim to be world leaders in this regard but do take pride in the fact that we have made progress and are happy to share our successes in the same way that we are happy to learn from others. 
 
 
 
It is quite possible that the world does not need another standard such as the DRF. As you pointed out there are already a large number of legislative and voluntary standards and programs. What excited us about the DRF was that it approached the problem not as another piece of compliance legislation but from the perspective of encouraging product reuse in a consumer driven fashion. We already know that there is a market for reused products in the wireless handset world. That market is what fuels and funds the trade in programs that we see today from many of the leading carriers. What is missing from that market is a set of standards that gives consumers confidence that the ‘refurbished’ products meet specific performance and quality standards. By creating such a standard the expectation is that consumers can have more confidence in renewed devices and thus drive a greater demand for recycling in an industry that produces over 1 Billion new devices every year. 
 
 
 
This is not something that we could ever hope to achieve ourselves. Even with the support of the other founding members of the forum we recognize that this needs a broader industry support to be successful. This is why the forum continues to recruit new members from across the wireless industry in parallel with the development of the first draft of the standard. 
 
 
 
Thanks again for the comments and sharing some of your obvious passion for the topic. We look forward to providing more updates on this in the coming months and to building more momentum in our own sustainability initiatives.