Alan Finlay, editor of Chakula, the APC Africa policy monitor, has submitted the following letter to the South African National Committee of the IEC on behalf of APC:
Jo-Anne Byng
Secretary: South African National Committee of the IEC
Private Bag X191
0001
Pretoria
Phone +27 12 428 6704
083 6284856
Fax +27 12 428 6889
Dear Ms. Byng,
The Association for Progressive Communications (www.apc.org) would like to appeal to you to support a call by environmentalists to consider voting against Clause 7 of IEC standard 62368. APC is a non-profit organisation active in the field of information and communications technology (ICT) policy development. Its membership is global.
Given our ICT focus area, we appeal to you to attend to the challenges presented by old technology, and the difficulties we experience in recycling these technologies. As you will know, e-waste is characterized as a hazardous waste by the Basel Convention, to which South Africa is a signatory.
Currently there are few sustainable options for recycling flame retardant plastics used in electronics, and any further chemical additions to these plastics could seriously worsen the problem.
We therefore seriously request that you consider voting ‘No’, with the comment that the IEC should not move forward on Clause 7 until there has been a study conducted on the fire safety rationale and the health and environmental impacts. We understand that Germany, Norway and Sweden are also likely to vote against Clause 7 of IEC standard 62368 and the UK and Ireland will likely vote against the entire standard.
If you are unable to vote ‘No’, please consider voting ‘Yes’ with a comment as follows:
“Prior to the publication of the FDIS for IEC 62368 (if Clause 7 remains in the draft), a safety impact report must be completed and circulated. The report should provide a fire safety justification for Clause 7; an estimate of the global increase (tons/year) of fire retardant chemicals in outer housings of audio, video, communications and information technology equipment assuming Clause 7 would be promulgated; and the resultant impact on human and environmental health.”
We recommend that members from IEC TC 108 and IEC TC 111 conduct the safety impact study and write the report, soliciting qualified academic and NGO input. APC would be prepared to be part of this assessment team, and we could recommend others whose skills would be invaluable in this context. To provide transparency, all the contributing individuals and their affiliations should be identified.
If the safety impact report is not available or does not provide data to justify Clause 7 before the FDIS publication, and Clause 7 remains in the FDIS, then the national bodies should consider voting down IEC 62368.
We understand that Clause 7 requires that the majority of electronics used in the home, such as TVs, computers, CD/DVD players, and more, withstand a three-minute vertical candle flame ignition test. Yet we have been informed that there is no reliable fire data proving the need to protect electronic products from candle ignition. Furthermore, in order to meet the requirements set forth by Clause 7 of IEC 62368, the electronics industry will be compelled to use large amounts of flame retardant chemicals, exposing consumers to potentially serious health risks.
As suggested, this standard will make recycling and electronic take-back systems more difficult, expensive, and in some cases, impossible.
Thank you for your consideration,
Alan Finlay
APC Africa ICT Policy Monitor Editor
e-mail: chakula@apc.org
tel: +27 011 726 4964