ELE0050
Written evidence submitted by EEESafe
Background
EEESafe is an SME with over 55+ combined years’ experience in Reuse, Repair, Recycling and Training on the repair of White Goods Appliances. We take the W out of WEEE and make the items safer.
The CEO Robert Alexander having set up a Charity and Reuse Warehouse Enfys Foundation (14k sq ft) and 3 charity shops, helping people with Waste prevention. Secured £337k funding and became the MD overseeing and setting up all operations. (Previously setting up a successful IT business from scratch, reaching Turnover of £1M starting from a bedroom) During this tenure of 10 years at the Charity, worked with two Local Authorities, Volunteer Organisations, Supporting People and other Registered agencies to helping tackle Poverty and Waste Prevention.
We supplied Local Authorities with Metrics of waste and Social Outcomes, and procured payment for the Charity. Also worked with 3 Producer Compliance Schemes and 3 Sector Skills Councils and established a business plan to implement a Qualification Model that would teach local Appliance repairs, with a view to scaling up across the UK.
Left to create EEESafe in and deliver our Award Winning Model for Sustainable Design, which is currently in development and close to first launch. See HERE
What steps are being taken to move towards a circular economy for electronic goods? How can the UK
Government support this transition?
What we’re attempting to do is to build community engagement model to incentivise and promote on the ground behavioural change, within every local community in the UK. Practical engagement with multiple Apps and building a rewarding Volunteer Currency working with local businesses, we believe can hasten citizens actions and create thriving communities. Our catalyst is our innovative Appliance Safety Register which will be Independent from Manufacturers control, their linked Warranty Sales in their own Register (Recommended by Government) and will develop a local recycled spares source from Waste Prevention. Research has shown around 30% of Consumers won’t Register an Appliance for some of these reasons. We will provide free Alerts on Recalls, which will still follow and provide recommended actions announced by Government& Manufacturers. We can also minimise the Sales or gifting of Product Recalled White Goods appliances in the Second use Market. This model can be expanded into ALL Electrical Goods and metrics of Carbon, Waste prevention and Social outcomes can be delivered in real time, attributable to citizens and concatenation of their Community metrics, to assist targets Local Authorities and Government must meet.
We own a set of Licenced Training Materials in Partnership with Dixons Training which includes a Training The Trainer Programme that could also deliver our own Qualification at scale. When we shortly establish our Trial Project Partner, we can begin to generate a Uk Wide network of Licenced Training centres, who can install thousands of local community repairers, who will then encourage citizens to register their appliances with ours. This can deliver mass engagement into the CE as well as provide local skilled people living in the communities, with mass evidence on the outcomes, metrics and make homes safer in a smart award-winning model.
Connected to this, will be our Training and Certification for independent Trusted Repairers in White Goods appliances, (with scope to add others). We have combined 50+ years experience of Training & Recycling of White Goods, where also we’ve found it a common theme, that Electricians are not competent or have enough depth of knowledge to effect safe repairs or refurbishment of White Goods. The Government met us and agreed on this where BEIS previously stated “that the skills of an electrician are not directly transferable to the repair of White Goods” Read our Article HERE which came after our meeting.
There are some good repairers out there, but we need to reduce the cowboys by first creating the professional standard similar to Gas Safe, but for the repairs of white goods such as washing machines, fridges and cookers. These would be known as Appliance Technicians (DATs..Home Visits) and Domestic Appliance Refurbishers (DARs…workshop only) They will be submitting evidence annually on being allowed to operate in the UK, have the correct insurance, calibrated equipment and prepared to submit repairs and readings, after also passing an online assessment application. DAR’s can be trained working with Rehabilitation Programmes as well, and we’re talking to an interested party right now.
Click Here where you will find forensics and evidence of causes of fires in White Goods. The depth of knowledge needed to help prevent and identify faults in White Goods, is not independently verified by anyone and we are seeking to introduce something the Public can Trust, using the EEESafe Standard. A standard where the course embeds the use of our own Appliance Register, offers routes to recycling/repair and evidences community metrics aligned to the CE, and Government objectives.
There is no independent Competent persons Scheme for White Goods repair, and current government guidelines for landlords and citizens are flawed in safety terms as well as EU adopted protocols. These protocols known as (UEEE) do not have independent evidenced competent persons bringing these items or electrical spares, back into circulation. Known as Preparing for Reuse and a British Standard PAS141, there are still risks associated with these goods. When compared with our Standard in White Goods, we are safer than a BSi. See brief analysis HERE We hold a more detailed report ourselves.
We continue to evidence to OPSS, the need for a Second Appliance Safety Register based on research but also because they offer no mitigation, for the large percentage of people who do not trust Manufacturers. We’ve seen even recently, the Whirlpool who had to be forced to recall their product and OPSS needs to recognise it will take years for people to change their minds. The corporate sector and stakeholders like Electrical Safety First and Amdea, have the interests of Electricians and Manufacturers at heart, because they are not interested in Recycled Spares or Appliances as they only want to sell new. We have been told that by some Manufacturers and actually warned away by some groups, not to interfere, for reasons such as some smaller repair companies would lose additional work given to them by Manufacturers. We maintain that the establishment of even more “in the neighbourhood” installed safe Community Repairers would and could have assisted in Recall repairs, more rapidly and more cost effectively. We have been excluded from some recent Government run initiatives on getting more people to register, which we believe has been by design. We’re currently working with OPSS on this and some MP’s, which also relate to the misguided information given to the Public and Landlords on PAT Testing. See our published article HERE as an illustration to support why guidance must change. There is an Early Day Motion that has been tabled, which shows MP’s appear to have been misguided, but we’re now assisting MP’s on this.
There are clear conflicts in the system here, all of which restrict more repair some of which appear commercially driven, where they should be driven by safety and environmental aims. Even WHICH has lost its consumer independency when it comes to White Goods. Clicking on their site and reports of brands and models, clearly shows there are click through revenues. Why is Government listing them as a partner, as like the Manufacturers Register, they are not clear of conflict and independence.
What is the environmental and human health risk from e-waste? How significant is it and who is most at risk?
The health risks are well documented and explained at the World Health Organisation site here.
https://www.who.int/ceh/risks/ewaste/en/
How can secondary markets for electrical goods be improved? What incentives are required to implement these markets?
The incentives now, all fall within the Producer Compliance Schemes. I’ve worked with 3 in the past, and all take goods away from local communities, repair and sell them back at a cost almost the same as the purchase of a new one. This puts jobs elsewhere, increases pollution through transportation, which increases energy demands and leaves less repair for the local skilled people. All the schemes I worked with took up to 50% profits from reuse organisations they worked locally with, which I was one reason why we needed to create skills and citizen engagement at the local level and reward and develop local economies. It’s a paradox really, because these people are targeted by evidence and quotas that must be met, operating with the Distributors Takeback Schemes. If they don’t have waste (Resource), then they don’t meet the targets and fines can be imposed. We need to change this system and ensure the highest local proximity rule for Waste Prevention and Safe repair. The future should be more regional reprocessing plants, that engage with citizen material sortation, rewarded by incentives such as we offer, and we are building in local collection groups of different materials, so that this provides local incomes, reducing demand on the Welfare budgets and delivering Social outcomes. As we live longer, we want more to do as it’s good for our well-being, and of course with us, the Environment and creating local funds to deliver more skills and reduce poverty.
We have already explained our Incentives and our methods of implementation, but we also intend to deliver cash funding to local communities, buy using our Register and it’s Charitable giving. In a new Social Charitable model, we will transparently create cash pots for the community, and Volunteer Currency both democratically awarded, and ring fenced from the community where the Waste Prevention arises. A short Video illustrates this. We believe that revenues created locally should be distributed locally, and not be subject to the decisions of large Waste Companies and their partners. Not for Profits whilst delivering some good outcomes, can pay them and their employees large sums of money, but we believe in making the Community and it’s members, the real investors. It’s why we refused Centrica’s investment of up to £2m, which would leave us nothing to tackle poverty at a local level.
Why does recovering materials from electronic waste pose a significant challenge? What support is required to facilitate the adoption of recovery technologies?
The current “demand” for waste through poorly designed systems where only the Corporates are in control, doesn’t allow consumer engagement that rewards them enough to prevent waste and effect repairs. We can change it by having support and engagement from the Governments collectively, who can benefit from the outcomes and evidence. Citizens, when properly organised are capable of better delivery if they are sufficiently incentivised, and have larger ownership, which we intend to provide. The challenge is to how to disrupt the existing model and deliver a more transparent community engaged system.
Are UK Waste Electrical and Electronic Equipment (WEEE) collection targets achievable? What challenges do UK producer compliance schemes and WEEE reprocessors face in meeting the collection targets?
They are achievable, but they will always go up. We suggest developing partnerships with our model and rethinking how Communities funding could be diverted into a model like ours. Partnership with PCS’s and other stakeholders can deliver the evidence metrics from citizens to help them meet these ever increasing targets, and pay the community for the data. This is what we’ve built into our Community platform. (LocalitEEE- Local Employment, Economy, Environment) Such partnerships should be built on Community asking for the right Assets, to enable this to work, and be community owned.
What causes fraud in the UK’s e-waste system? How can this be addressed?
In a way not normally viewed, perhaps the demand to run something that isn’t profitable enough. Investors demand profit to suit their lifestyles. Highly Paid staff must also be paid, so it then becomes difficult to make it pay and temptation must play a part. We perhaps need to work to a partnership of business and community with Responsible Consumption at the heart of it. The worlds Richest 1% own 82% of the Worlds wealth. Greed is the fuel of poverty. There is actually enough resources in the world to rid ourselves of inequality, and it’s within the gift of every citizen to help change this, but only in Partnership with the Rich. This is a core objective and end game of what we believe. We must live within our means and most of our model aligns with Kate Raworth’s Doughnut Economics (if you like, the academic version of our model). There are of course other factors which you will read of from the PCS, and particularly the new Producer Balancing System that is coming into effect.
What action can the UK Government take to prevent to the illegal export of e-waste to the developing world?
Invest in regional infrastructure for more reprocessing on the GB Island. Then engage local material collection and sort groups from Electrical waste. Properly organised, sorted material can be used for Repair/Reuse but the surplus can be sorted and sold for Community Benefit. We’re scoping a Dismantling Certification/Qualification as well, which can include Small as well as Large Appliances. As we are an Island, and import Appliances, we need to retain the valuable social, environmental and Critical Raw Material content and become less dependent on imports in the long term.
What proposals does the UK Government need to consider as part of its consultation on WEEE?
We’ve been working with the OPSS on this and recent meetings are showing some progress. We’ve challenged current legislation and guidelines because they are flawed and misleading in terms of Electrical Safety in White Goods reuse/repair. Some of these have already been mentioned, however as we’re advocating that Safe Repair & Recycling is a strong process and model to help prevent EEE Waste, it’s recognised that BEIS and OPSS have identified Right To Repair as something that is on their radar.
We have produced a short Blog on things that need to be considered, and therefore we believe this should be taken into consideration of any WEEE Consultation. It can be found at THIS LINK and it covers things that will impact the volume of EEEWaste as well as citizens safety. These include, Landlords, Repair Cafes, Brand Damage, Online guides and the risks associated with unaccountability of electrical used repairers.
Is UK public awareness of e-waste recycling satisfactory? If not, how can it be improved?
We’ve already explained what our intentions are and we will be doing this alongside any other programme anyone else runs. This includes our Register and without proper debate and dealing with the safety and environmental issues we help to solve, there is going to be a mixed message coming from Government whilst our evidence remains unaddressed at the highest level. There is value in Waste, which we prefer to call “resource”, and we will be educating citizens and communities on how to maximise revenues whilst tackling poverty and the environment. It can be improved by better partnership working and recognising the benefits we can bring to the table, together with allowing us scaleable international growth. The same issues exist throughout the world, but a Standard Affiliated to a Currency that is not Crypto and works through Volunteering initially, is a glue for mass change. We worked with an EU Project on Funding through H2020, and they liked our whole model. We failed to get the final round, but clearly the evidence is there of our potentiality, which when delivered strategically, can have a huge impact in sustainable management of Electrical Waste.