“1500 tons of used medical devices are shipped yearly to non-OECD countries (China, India and Malaysia only) for RRR activities. DITTA estimates that 84 tons of waste is generated in those countries per year, most of which is non-hazardous. 100% of the waste is treated locally by facilities with environmental certifications.

DITTA also estimates that 672 tons of used equipment are shipped per year worldwide for root cause analysis, and only 61 tons to the same three non-OECD countries. Root cause analysis is a mandatory requirement for manufacturers to ensure the highest level of safety for medical devices.
In 2014 China, India and Malaysia generated 7.9 million tons of e-waste. The waste generated by refurbishment and root cause analysis activities (145 tons in total) accounts for less than 0.0018% of the total.”

From p. 2 of response by Global Diagnostic Imaging, Healthcare IT & Radiation Therapy Trade Association (DITTA) to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/Conferen

ceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.

“The ICT sector strongly supports the environmentally sound management (ESM) of any residual hazardous wastes (including any wastes with unknown hazardous characteristics) generated as a result of permissible failure analysis, repair and refurbishment activities. We agree that such wastes must be managed in accordance with the Basel Convention.

We support the approach now set forth in the TGs concerning the use of contracts between the person managing transport and the receiving facility to ensure ESM of residual wastes from failure analysis, repair or refurbishment activities. The use of such contracts along with appropriate documentation and feedback reports reduces greatly the risk of improper management of residual wastes.

A requirement to return residual hazardous wastes to the country from which the used equipment originates is impractical and unnecessary. In some cases, non-OECD countries may boast better ESM facilities than certain OECD countries. Rather than prescribing arbitrary practices, the common objective of all stakeholders should be to ensure that all covered wastes are managed in an environmentally sound manner. This can be accomplished in the country that hosts the failure analysis, repair or refurbishment operations or in a nearby country if the first lacks such ESM facilities.”

From p. 6-7 of Information Technology Industry Council (ITI) response to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx