Greenpeace Strikes Again with Its Unscientific Electronics Scorecard

In October, Greenpeace issued the sixteenth revision to their electronic scorecard, “Guide to Greener Electronics.”  The guide rates consumer electronics companies against Greenpeace criteria on hazardous substances, take back and recycling and energy use and climate change.

In their January 2010 scorecard, Greenpeace not only asked companies to change materials used in their product, they also took a bigger step in requiring companies to lobby on behalf of their agenda. In that scorecard, criterion C1 was amended, “requiring companies to also actively lobby for the addition of an end-of-life methodology for further restrictions of hazardous substances and for organochlorines and organobromines to be added to the list of substances already banned by the EU RoHS (Restriction of Hazardous Substances in electronics) Directive, currently being revised (RoHS 2.0).”1

With the issuing of the October 2010 edition of the scorecard, Greenpeace continues to mark down leading consumer electronics manufacturers for failing to lobby for an agenda based on faulty science. Several computer manufacturers received lower scores for failing to “openly support restrictions on at least PVC vinyl plastic, chlorinated flame retardants (CFRs) and brominated flame retardants (BFRs) …”

Why is Greenpeace trying to exert control over what companies say?  Perhaps it’s because they know that an honest discussion of the facts and evidence regarding specific BFRs, like Tetrabromobisphenol-A (TBBPA), which provides flame retardancy to more than 80 percent of all printed boards, would fail to support their unscientific position that a green product must not contain TBBPA. The World Health Organization2 and the European Commission’s Scientific Committee on Health and Environmental Risks (SCHER)3 conducted separate, comprehensive scientific assessments of TBBPA and both found TBBPA to be safe for human health and the environment.

Just in case companies aren’t clear about what Greenpeace wants them to say, the Guide to Greener Electronics, Ranking Criteria Explained 4 provides a copy of the statement it wants posted on electronics companies’ websites which begins, “[Company name] is committed to the elimination of the most toxic chemicals, starting with BFRs and PVC, from our entire product range. In order to ensure this is achieved across our industry as quickly as possible, we ask EU regulators to amend the European Commission proposal of December 2008 for a revised RoHS Directive …”

In support of open discussion we offer the following thoughts on the Greenpeace ranking criteria for toxic chemicals.5

Ranking Criteria:     Substituting harmful chemicals in the production of electronics will prevent worker exposure to these substances and contamination of communities that neighbor production facilities.
Fact:           The World Health Organization6 and the European Commission's Scientific Committee on Health and Environmental Risks (SCHER)7 conducted separate, comprehensive scientific assessments of TBBPA and both found TBBPA to be safe for human health and the environment.
Fact: In Europe, the flame retardant industry's Voluntary Emissions Control Action Programme (VECAP) has reduced manufacturing-related releases of TBBPA to air and water to less than one kilogram total in 2009.8
Ranking Criteria: Eliminating harmful substances will also prevent leaching/offgassing of chemicals like brominated flame retardants (BFR) during use, and enable electronic scrap to be safely recycled.
Fact: TBBPA is chemically bound into the plastic matrix of the printed board and therefore is not chemically available (for leaching or offgassing) during use.9
Fact: Metals are reclaimed from waste printed boards through incineration. Regulated, controlled incineration of bromine- and chlorine-containing materials does not pose a problem for human health or the environment.10,11
Ranking Criteria: The presence of toxic substances in electronics perpetuates the toxic cycle – during reprocessing of electronic waste and by using contaminated secondary materials to make new products.
Fact: The World Health Organization12 and the European Commission Scientific Committee on Health and Environmental Risks (SCHER)13 conducted separate, comprehensive scientific assessments of TBBPA and both found TBBPA to be safe for human health and the environment.
Fact: Current best management of end-of-life circuit boards is energy and metals recovery through controlled incineration. Regulated, controlled incineration of bromine- and chlorine-containing materials does not pose a problem for human health or the environment.
Ranking Criteria: The issue of toxicity is overarching. Until the use of toxic substances is eliminated, it is impossible to secure “safe” recycling.
Fact: Regulated, controlled incineration of bromine- and chlorine-containing materials does not pose a problem for human health or the environment.14,15

1 Guide to Greener Electronics, Ranking Criteria Explained, Greenpeace, January 2010
2 An Overview of Alternatives to Tetrabromobisphenol-A (TBBPA) and Hexabromocyclododecane (HBCD). March 2006.
http://www.sustainableproduction.org/downloads/AternativestoTBBPAandHBCD.pdf

3 2,2’,6,6’ – Tetrabromo-4,4’-Isopropylidene Diphenol (Tetrabromobisphenol-A) Environmental Part. January 15, 2008.
http://ec.europa.eu/health/ph_risk/committees/04_scher/docs/scher_o_071.pdf.

4 Guide to Greener Electronics, Ranking Criteria Explained, Greenpeace October 2010
5 Ibid
6 An Overview of Alternatives to Tetrabromobisphenol-A (TBBPA) and Hexabromocyclododecane (HBCD). March 2006.
http://www.sustainableproduction.org/downloads/AternativestoTBBPAandHBCD.pdf

7 2,2’,6,6’ – Tetrabromo-4,4’-Isopropylidene Diphenol (Tetrabromobisphenol-A) Environmental Part. January 15, 2008.
http://ec.europa.eu/health/ph_risk/committees/04_scher/docs/scher_o_071.pdf.

8 Measureable Achievements Annual Progress Report 2009 (Europe), VECAP.
http://www.vecap.info/uploads/VECAP_report_22%2001.pdf

9 FLAME RETARDANTS IN PRINTED CIRCUIT BOARDS, Review Draft, US EPA 2008.
10 Waste-to-energy: A review of the status and benefits in USA, C.S. Psomopoulos, A. Bourka , N.J. Themelis, Waste Management 29 (2009) 1718–1724.
11 “The impact on health of emissions to air from municipal waste incinerators,” Health Protection Agency, September, 2009.
http://www.hpa.org.uk/web/HPAwebFile/HPAweb_C/1251473372218 (.pdf)

12An Overview of Alternatives to Tetrabromobisphenol-A (TBBPA) and Hexabromocyclododecane (HBCD). March 2006.
http://www.sustainableproduction.org/downloads/AternativestoTBBPAandHBCD.pdf

13 2,2’,6,6’ – Tetrabromo-4,4’-Isopropylidene Diphenol (Tetrabromobisphenol-A) Environmental Part. January 15, 2008.
http://ec.europa.eu/health/ph_risk/committees/04_scher/docs/scher_o_071.pdf.

14 Measureable Achievements Annual Progress Report 2009 (Europe)...
15 FLAME RETARDANTS IN PRINTED CIRCUIT BOARDS...
16 Measureable Achievements. Annual Progress Report 2009 (Europe)...
17FLAME RETARDANTS IN PRINTED CIRCUIT BOARDS...
Industry