The RBRC is non-profit corporation established in
1994 (not 1996). We have a twofold mission: to educate consumers on the
importance of Ni-Cd battery recycling and to serve as the leader in the
environmentally safe collection, transportation and recycling of rechargeable
A valid correction - the RBRC was established in 1994. However
it was not until June of 1996 that major retailers were solicited to join
the program. Based upon this correction, the RBRC program has been in operation
for 4.5 years in the U.S. (not 2.5 years as claimed by the article). This
correction only serves to highlight that Ni-Cd battery recovery rates are
even lower than expected given that the program has operated for five years
(rather than only three).
At no time has the US trade association representing the rechargeable
power industry, PRBA (Portable Rechargeable Battery Association), operated
The article does not state nor insinuate that the PRBA has
ever operated in Canada. The article asserts only that the PRBA's function
as described in the U.S. is also fulfilled by the RBRC in Canada.
The RBRC's Ni-Cd battery collection and recycling program is different
in the United States than in Canada, with the former being more comprehensive
in collection options. The RBRC is working in co-operation with federal
and provincial governments to adjust the current hazardous waste manifesting
requirements to be able to expand the collection options from the current
retail and licensee program to community, business and public agency collection
It is not clear what point in the article is being refuted
or clarified by this comment. Given the length of time in which the PRBA
and RBRC have been operating in the U.S. it is not surprising that the
programs are different if not, "more comprehensive in collection options"
(whatever that means).
As clarification it should be noted that in the U.S. the federal
battery law introduced in May of 1996 effectively achieved what the RBRC
says that it is still working on - "to adjust the current hazardous waste
manifesting requirements." Furthermore, in his article in State Recycling
Laws Update of Mr. Robert Guyer (the chief lobbyist for the RBRC in the
U.S.) gave no indication that U.S. hazardous waste manifesting rules continue
to be a barrier to Ni-Cd battery recycling. As mentioned in the article,
many U.S. businesses and public agencies already have their batteries collected
either for containment in a hazardous waste landfill or for recycling.
The point of the article is that most of the RBRC batteries already originate
from these sectors and not from the retail sector (whose customers are
the primary generators of used Ni-Cd batteries).
In addition to the retail partners Canadian Tire, RadioShack, Zellers,
Blacks Photography, Astral Photo Images and Battery Plus, participating
Authorized Motorola Dealers, Makita Service Centres, Personal
Edge and Centre de Rasoir. In total, the RBRC program is available through
over 3,000 (not 2,000) retail outlets throughout Canada. In total, over
25,000 retail outlets throughout Canada and the United States are supporting
the RBRC recycling program.
All numbers and lists of participating retailers were drawn from
the RBRC web site as cited below. The Canadian program is described as
"Patterned after a similar program developed in the United States
that has proved to be an enormous success since it began, RBRC expects
to see even better results in Canada, where its affiliated business partners
include a combined total of more than 1,900 retail outlets of Canadian
Tire, RadioShack, Zellers, Blacks Photography, Astral Photo Images, and
Quoted from the RBRC Web Page (http://www.rbrc.com/Ottawa.htm)
as CREATED: Dec. 09, 1996 and MODIFIED: Feb 3, 1997
Further embellishments of the numbers in the article
provide no additional information regarding the efficacy of the RBRC's
battery recovery program.
The RBRC program has resulted in the diversion and recycling of over
14 million pounds of Ni-Cd batteries rather than being thrown in landfills
in the past 4 years. In 19996, RBRC's recycling rate was 15%. In 1997,
our program recorded a + 46% growth, realizing a 22% recycling rate.
In the 1998 year end edition State Recycling Laws Update Jefferson
C. Bagby an associate of Mr. Robert Guyer (the chief lobbyist for the RBRC
in the U.S.) reported the following:
"The Rechargeable Battery Recycling Corporation (RBRC) reports that
for 1997 it recycled 22% of the small sealed rechargeable Ni-Cd batteries
in the U.S. This is a 7% increase over the 1996 recycling rate of 15%."
Mr. Kelly repeats the numbers I quoted from State Recycling Laws
but converts absolute change (7%) to a growth rate (46%) ñ a twist of the
numbers. How does this correct or improve what I wrote?
Furthermore, while 14 million pounds of Ni-Cd may have been recycled
over 4 years, it is important to note that the bulk of these batteries
were already being managed by the ICI sector and that little of that stream
represents new diversion away from the municipal waste stream. It seems
that all the RBRC did was re-channel an existing flow of recovered batteries
through its own program.
The RBRC program is committed to recycling (not landfilling) the
Ni-Cd batteries collected through our efforts. We have provided stringent
instructions to supply all our supplies - which are reinforced through
a rigorous audit process - to ensure our recycling mission is achieved.
The efforts our battery recycler - Inmetco - have been recognized by many
external organizations for their recyling achievements. In fact, EPA Deputy
Assistant Administrator, James Matthews, stated after an inspection of
INMETCO that "none of the by-products of this facility are sent to landfills."
I take the RBRC's commitment to recycling Ni-Cd batteries at
face value. However, its comments regarding Ontario's proposed MCN regulation
speak for themselves. I find it interesting that Mr. Kelly did not choose
to "clarify" either the RBRC's comments to the MOE as reproduced in the
article, or my interpretation of their comments.
The article does not state nor insinuate that any batteries sent
to INMETCO are sent to landfill. Rather it points out that given the costs
of shipping batteries from Ontario to INMETCO and the RBRC's own comments
in this regard, that (if the RBRC had its own way) it is likely that Ni-Cd
batteries collected in Ontario would never make it to INMETCO.
Our program has been designed to maximize efficiencies in collection
transportation and recycling efforts. Wherever possible, we encourage our
collection sites to ship directly to INMETCO.
I'm not sure what point in the article is being refuted or corrected
Similar to other waste streams, the IC&I sector represents a
substantial source for used Ni-Cds. RBRC spends considerable effort to
ensure that collection results from IC&I sources are maximized. Added
to this, the retail collection program was created to capture the Ni-Cds
from consumers. Our market research indicated that it was logical to put
collection containers as retail consumers were bringing their used Ni-Cds
with them to the store to ensure correct purchase of replacements. RBRC
has devoted considerable effort to implement retail staff training programs
to ensure we maximize the collection of used Ni-Cd batteries from retail.
I have no information to counter the claim that the return-to-retail
program was the result of market research. However, with the State of Minnesota
requiring a 90% Ni-Cd battery recovery rate, (unachieved to this date)
I would imagine it would be difficult to convince state legislators of
the seriousness of the program without a return-to-retail program component.
The contention that, "RBRC has devoted considerable effort to implement
retail staff training programs to ensure we maximize the collection of
used Ni-Cd batteries from retail" is a non-sequitur. The real issue is
how to get consumers to return batteries to retailers in the first place.
Where is the incentive? How does staff training have any significant impact
on consumer return rates of Ni-Cd batteries?
Again the efficiency sake, the RBRC was created to help our over
25 member companies to implement an effective recyling program collectively
rather than through individual efforts. Our members evaluate our efforts
based on collection rates. We are expected to deliver high collection rate
results (not avoid them). I do not believe that "relatively little effort"