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BI logo

Report on the Lead Risk Reduction Activities of the International Lead Management Center (June 2008)

Prepared by Brian Wilson, Program Manager

Index

Summary

ILMC Activity Summary December 2007 to June 2008.

  1. SBC ULAB Projects 
    • Central America, the Caribbean, Colombia and Venezuela

The Regional Strategy agreed by all the participating countries in the Region has been revised by the ILMC to reflect changing circumstances in the region and the document agreed by the respective BCRCs in El Salvador and Trinidad and Tobago. The SBC will now publish the Strategy and distribute it to the participants.

http://www.ilmc.org/Basel%20Project/Strategy/2008/Revised%20Regional%20Strategy%20ULAB%20May%202008.pdf

The proposal for a four year project to implement the agreed Regional Strategy has been prepared and agreed with the SBC. The SBC will now present the proposal to the COP 9 in Bali during the meetings which run from 23-27 June 2008, in order to seek funding.

http://www.ilmc.org/Basel%20Project/Implementation/IMPLEMENTATION%20PLAN%20First%20draft%20SBC%2028%20May%202008.pdf

Following the publication of the ILMC visit report to Guatemala and the assessment of the Acumuladores Iberia SA ULAB recycling plant, the SBC will invite the Government of Guatemala to join the next phase of the ULAB recovery project because the country has a smelter that conforms to the Basel Technical Guidelines for the recovery of ULAB and it could be a key player in the region.

http://www.ilmc.org/Basel%20Project/Guatemala/Mission%20Report/Mission%20Report%20for%20Guatemala%20February%202008.pdf

At the request of the Environment Ministry in El Salvador the ILMC conducted an empirical survey of the premises of Grupo Record in San Salvador following the closure of the recycling and battery manufacturing plants by the Health Ministry, to determine the nature of the hazardous wastes left on the site and the implications for the Government under the Basel Convention.

At the urgent request of the Government of Senegal the ILMC were invited to conduct a Technical Mission on behalf of the SBC to instigate the introduction of environmentally sound recovery practices for ULAB following the deaths of eighteen infants at an informal domestic recycling operation.

This mission was undertaken with the Blacksmith Institute because of the likely requirement for extensive remediation in and around the houses contaminated by the informal ULAB recycling.

Technical assistance for any follow up mission or project in Senegal has been offered to the ILMC by Frys Metals in South Africa.

Full reports for the mission including recommendations for sound ULAB recycling are currently under consideration by the Government.

Status of Current Activities

SBC Regional ULAB Recovery Project

Since 2000 the ILMC has been providing technical support to the Secretariat to the Basel Convention in respect of Lead Risk Reduction.

The first project that the ILMC were invited to participate was the preparation of the Basel Technical Guidelines for the Environmentally Sound Management of Used Lead Acid Batteries.

The Conference of the Parties at its fifth meeting adopted the Ministerial Declaration on the Environmentally Sound Management. This declaration marked an important shift in focus of the convention by giving due consideration to the needs of the countries to develop hazardous waste ESM policies, in addition to controlling transboundary movements.

In this context, the SBC initiated a ULAB Recovery Project in Central and South America and the Caribbean which was selected as a priority project for funding under the (limited) financial mechanism put at the disposal of the parties for the implementation of the Ministerial Declaration.

In January 2001 the ILMC joined a multi-stakeholder team assigned to assist with the design and implementation of a Regional Project for the Environmentally Sound Recovery of ULAB in Central America, Colombia, Venezuela and the Caribbean Island States.

Regional Project Objectives for the Environmentally Sound Recovery of ULAB

A comprehensive review of the existing national and regional systems for the management of ULAB in 9 target countries, including the applied regulatory and economic instruments for collection and recycling, technical requirements, environmental and occupational practices, existing public-private partnerships and autonomous private sector campaigns, and the transboundary movements of battery scrap.

A preliminary assessment of the requirements for implementing ESM of used lead-acid batteries, including recommendations for waste prevention, at national and sub-regional levels.

Discussion with policy makers and private sector representatives regarding elements of practicable national and sub-regional strategies for ESM of used lead-acid batteries, including appropriate forms of public-private partnerships for assuring environmentally sound and economically viable battery scrap collection and lead recovery. Key outcomes would be:

       1. Improved ULAB recovery rates
       2. Reduced occupational and population lead exposure
       3. The minimization of the environmental impact of ULAB recovery
           
The opportunity would also be taken to explore options to resolve any lead exposure issues and contamination problems on a regional basis.

Participating Countries

The nine Countries participating in the Pilot study are; Mexico, El Salvador, Costa Rica, Panama, Colombia, Venezuela, Trinidad and Tobago, St Lucia and the Dominican Republic.

Project activities have been coordinated by the Basel Convention Regional Centers for Training and Technology Transfer (BCRCs) in San Salvador (MARN) (for Central America) and Trinidad and Tobago (for the Caribbean) with support from the Basel Secretariat (SBC). Assistance has also been given by the University of the West Indies (UWI) through its Department of Chemistry in Trinidad, the United Nations Conference on Trade and Development (UNCTAD) and the International Lead Management Center (ILMC).

Trinidad Workshop I

Prior to the start of the study a project launching two-day workshop was held in Trinidad in May 2001. Attendance was limited to the national coordinators of the project from each target country and representatives of the BCRC in San Salvador and Trinidad, the Cleaner Production Centers (NCPC) in the participating countries, the SBC, UNCTAD, and the ILMC.

The Workshop provided an ideal forum to:

  • Confirm and explain the terms of reference for the project;
  • Determine and agree the relevant data and information that would need to be collected in the country assessment phase;
  • Decide where and how to find the best information sources;
  • Establish the extent and scope of the field surveys;
  • Set out an agreed timetable for data collection and assimilation;
  • Facilitate the planning of the second phase of the project involving the collation and interpretation of the information collected in the first phase and a second workshop to consider and discuss the results of the study to decide on the most appropriate national and regional strategies for the ESM of ULAB.

 Action Plan

After discussion of the many exposure issues facing the participating countries, all delegates agreed that the study should proceed on the following basis:

  • The assessment phase would aim to tabulate relevant legal requirements, automotive battery consumption statistics, estimate annual leaded scrap generation, determine the export and import of lead containing scrap, ULAB collection schemes and develop a list of the recycling facilities.
  • The field surveys, including those undertaken by the ILMC, would assess environmental and occupational performance levels at recyclers identified in the first part of the study.
  • CARIRI would conduct a legislative survey of the participating countries.
  • ILMC would complete a technical survey of the processes found in use in the region and assess the potential for improved environmental performance.
  • A second regional battery recycling workshop targeting the countries in Central America and the Caribbean would then be convened to discuss the findings of the assessment phase; examine the various lead exposure issues; review options for the design and implementation of appropriate national ESM Strategies for battery collection and recycling; and consider possibilities for regional cooperation.

San Salvador Workshop I

The Second Workshop was duly held in November 2002 in El Salvador with the purpose of providing a forum for:

  • Country Delegates to formally report the results of the National Surveys.
  • Feedback from the SBC’s Analysis of the transboundary movements of ULAB in the Region.
  • The ILMC to outline their recommendations for improving ESM arising from the Technical Survey of Recyclers.
  • CARIRI to report to the Delegates an overview of relevant legislation in the Region that impact on the Management of ULAB, including National legislation and International Conventions or Protocols.

The Workshop also provided an opportunity for the Delegates to discuss the issues associated with the ESM of ULAB and Develop possible Regional Strategies.

It was also necessary for the Delegates to agree a set of principles that would apply to the Project and guide those involved in decision making.
 
In addition to the countries participating in the study, Representatives from the following countries also attended the San Salvador workshop; Venezuela, Guatemala, Belize, Honduras, Nicaragua, Ecuador, Brazil, Dominica, Cuba, Jamaica and Bermuda.

Transboundary Movement of ULAB

The study clearly identified the transboundary movements of ULAB in the region.

            ULAB are shipped or transported from:

  • The USA to Mexico
  • Guatemala, Honduras, Nicaragua and Costa Rica to El Salvador
  • Also Costa Rica to Panama
  • Trinidad and Tobago, St. Lucia and the Dominican Republic to Venezuela

Unfortunately not all of the transboundary movements of ULAB were found to be legal and in compliance with the Basel Convention and this was especially true in Central America.

Furthermore only two countries, namely Trinidad and Mexico demonstrated full compliance with the Basel Technical Guidelines for the storage, packaging and transport of ULAB.

Recycling Plant Visits

In the course of the Study the ILMC visited ULAB Collection Centers and Recycling Plants in Trinidad and Tobago, El Salvador, the Dominican Republic, Mexico and Venezuela. Each facility was assessed for ESM and compliance with the Basel Technical Guidelines.

Best Practices

The site visits confirmed that within the region there were excellent examples of “Best Practices” at every stage of the cycle in the ESM of ULAB.

  • Baterias de El Salvador has the most impressive network to collect ULAB in El Salvador, Costa Rica, Nicaragua and Guatemala.
  • Automotive Components in Trinidad have the best packaging operation for the export ULAB.
  • And two smelters are World Class, the ENERTEC plant in Monterrey, Mexico, and the Duncan Group’s plant, Fundicion del Centro at Turmero in Venezuela.
  • The most comprehensive legislation covering all aspects of ULAB recovery including health, safety, environmental and trade issues was found to be in Mexico.

Delegates attending the Workshop were urged to encourage their respective governments and industry sectors to share the expertise that’s within the region in order to raise standards and improve environmental performance. They also agreed that the Mexican Environmental Legislation would be the “model” for the region.

Regional Problems

 As a result of the analysis of the Country Reports and the Site visits the list of those issues deemed to be caused by technical deficiencies or poor operating practices were:

  • Abandoned or orphaned stockpiles of ULAB.
  • A lack of information and awareness of the risks of improper recovery of ULAB.
  • Significant environmentally unfriendly ULAB reconditioning in the informal and unregulated sector.

Non-compliance with:

  • The Basel Guidelines for the ESM of ULAB.
  • The Basel Convention for the transboundary shipment of ULAB (i.e. Hazardous Waste), except for companies in Mexico and one company in Trinidad.

The country assessments presented to the workshop delegates, and discussed by them in “break out” sessions, showed conclusively that there were a number of recurring themes that posed serious threats to the Region’s terrestrial and marine environments, and certain populations. The list of those problems deemed to be caused by Structural deficiencies is:

  • An absence of government inspection and monitoring of ULAB recycling sites.
  • A dearth of suitable long term financing for smaller companies wishing to improve their ESM of ULAB.
  • Inadequate infrastructure to support ULAB collection, storage, transport and recovery.
  • Dispersed institutional responsibility and disjointed coordination for regulatory affairs, health and the environment.
  • Protracted official bureaucratic procedures for the administration of environmental legislative procedures.
  • Insufficient and inconsistent legislative and regulatory frameworks for the control of ULAB recovery together with little or no enforcement of the regulations.

There were also concerns about unsatisfactory ULAB management underlined by the fact that in most countries there was little or no data relating to ULAB collection rates, trans-boundary movements and environmental monitoring in and around recycling plants.

Regional Synergies

The Country Reports revealed that synergies within the region lend themselves to solutions if countries help each other to resolve lead exposure or environmental contamination issues.

In this context four countries have environmentally sound recycling facilities, but the majority do not and are unlikely to ever have recycling plants as the amount of ULAB generated annually is insufficient to render such an enterprise viable.

All the countries in the Study are parties to the Basel Convention and accept the need to comply with the requirements for the control of the transboundary movement of hazardous waste and hence the need to monitor and document the transport of ULAB.

The major secondary lead plants in the region share a common technology for the recycling of ULAB, that is, Rotary Furnace technology, and surprisingly, due to the regional geography the companies are not competing with each other for ULAB. Hence there is everything to gain without compromising their respective businesses or giving a competitor an advantage.

Recommendations

Towards the end of the three day workshop recommendations were consolidated:

  • To develop harmonized policies for ULAB amongst the countries of the region.
  • To improve coordination amongst the appropriate national authorities responsible for the implementation of the Basel Convention and to establish greater control of customs procedures for the transboundary movement of ULAB. This would also include improved training for customs officers.
  • To define performance indicators for ESM and develop an Assessment Scheme.
  • To implement, in full, the terms of the Basel Convention for the trans-boundary movement of hazardous waste, especially those regulations applicable to ULAB, taking into account the realities of such an undertaking in the region. One suggestion to promote compliance was the creation of a regional technical group to establish the standards and proper procedures.
  • Increased surveillance of ULAB movements leading to full compliance with bilateral and multilateral agreements and better control of the illicit traffic in ULAB across borders.
  • Prepare National Strategies covering the Legal, Institutional and Technical Issues.

San Salvador Declaration

At the end of the workshop the delegates committed themselves to the following Principles contained in the “San Salvador Declaration” for the Environmentally Sound Management of ULAB.

  1. To implement the recommendations made by the delegates.
  2. To facilitate the implementation and compliance, in all the various aspects:
  • The Basel Convention and the Regional Agreement on Transboundary Movement of Hazardous Waste.
  • To promote the adoption and dissemination in all the countries in the region the Basel Convention technical guidelines for the environmentally sound management of used lead acid batteries with particular attention paid to the adverse impact that the inadequate management of used lead acid battery wastes causes to human health and the environment.
  • To develop education programs to sensitize:
    • Workers to safe and hygienic working practices for the recovery of ULAB
    • Children, and in particular their parents, to health education and surveillance programs
    • Members of the general public to the dangers to public health and the environment of improper handling of used lead acid batteries.

 Caracas Review

In December 2003 the Project Steering Committee met in Caracas, Venezuela, to review progress and with the following objectives:

  • To agree a uniform or “model” approach to ESM for the Project participants.
  • To define a role for the “informals” in order to regulate their activities and move them into the formal sector.
  • To develop a Training Manual containing the essential elements of ESM that could be used in education programs for Regulators, Customs Officers, Recyclers and the General Public.
  • A comprehensive Regional Strategy. 

ILMC provided an overview of ULAB Recycling in the Region based on the Pilot Country Inventories.

ESM Model for ULAB

Those representatives of Countries participating in the first phases of the project were now into the third year of the project and in a position to set out a logical procedure outlining how ESM should be achieved.

In summary:

  • The first stage is to complete an inventory of the likely sources of ULAB and the methods of recovery.
  • Secondly Public awareness of the risks associated with poor ULAB recovery must be established.
  • Current regulations and instruments need to be critically reviewed to highlight shortcomings in legislation or enforcement.
  • Because of the persistent environment and health risks posed by illegal recovery operations it is important to track down all such operations.
  • Current practices for the collection and storage of ULAB have to be observed and compared to the procedures published in the Basel Technical Guidelines.
  • The transport or shipping of ULAB has to be checked for compliance with safe working practices and the Basel Convention for the transboundary movement of ULAB.
  • For those countries without smelting capacity the model ends at step number 6, but those countries with smelters proceed to the final stage to consider the environmental performance of the recyclers.  

 The consensus reached by the delegates in Caracas on the seven step process for the determination of Environmentally Sound Management (ESM) of Used Lead Acid Batteries (ULAB) was a significant milestone.

The delegates also agreed that the “formalization” of the “informal sector” would be best achieved by education and the provision of opportunities for those in the informal sector to collect ULAB for shipment to a licensed smelter.

The Regional Strategy took a further step forward in Caracas with the general agreement that ULAB would only be sent to licensed and Environmentally Sound Recyclers and in this context the ILMC were charged with the responsibility to prepare an Assessment procedure for use by Governments and Industry.

Training Manual for the Preparation of a National Strategy

It was also clear at the Caracas meeting that there was a need for a comprehensive Training Manual that the BCRCs could use both “in house”, at local training sessions and “on the job” in factories and offices, to fully explain the processes required for the compilation of ULAB inventories and the implementation of environmentally sound and safe working practices outlined in the Basel Technical Guidelines.

Chapter one of the manual outlines precisely how to conduct an accurate national survey and present the results. Chapter two provides a range illustrations, graphics and interactive examples of best practice for ULAB collection, storage, transport and shipping. Chapters 3 & 4 deal with the different strategies required to control the environmental performance of the formal sector and eliminate the undesirable activities in the “informals”.

Communication, information and education issues, including public awareness and community engagement are covered in Chapter 5. Of concern to nearly all the governments in the region is Site Remediation and cost effective options are outlined in Chapter 6. Chapter 7 cover the essential elements of occupational health and safety at every stage to the ULAB recovery process.

Chapter 8 provides a step by step explanation of the Basel Convention’s requirements and obligations concerning the control of Transboundary Movements of ULAB.

 San Salvador Workshop II

In January this year workshop in San Salvador with the following objectives to finalize:

  • The National ULAB Inventory Reports.
  • The National Strategies and Action plans for implementation.
  • ESM Assessment Mechanism.
  • Regional ESM Strategies for ULAB

And to:

  • Prepare for the next Phase of the project

In January this year there was a Second Steering Committee Meeting of the ULAB project hosted by the BCRC-El Salvador and supported by the BCRC- Trinidad and Tobago and the Basel Secretariat. There were 33 representatives from 12 countries in the Region; Barbados, Colombia, Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Jamaica, Mexico, Nicaragua, Panama, Trinidad and Tobago and the following organizations; the Central American Commission on Environment and Development (CCAD), Environment West Indies (EWI, Martinique), University of West Indies (UWI), the International Lead Management Center (ILMC), and from El Salvador the Ministries of Environment and Natural Resources, Finances, Health, Baterias de El Salvador, Bateri­as Laser-El Salvador, the University of El Salvador and the local Fire Department.

National Policy was a main focus of the first sessions, but the delegates also reviewed the draft regional strategy developed in collaboration with the Regional governments, industry, academia and international organizations to achieve in the long term the environmentally sound management of ULAB. The discussions included consideration of the elements of a financial strategy and political support to realize the implementation of the project.

The country presentations focused on the background information for the project and the various stages of implementation of the Environmentally Sound Management (ESM) of ULAB in the participating countries; the Training Manual for the recovery of ULAB National ESM Strategies; the principles of ESM of ULAB and the Green Lead Initiative, including the Assessment of ESM.

The national presentations generated some very interesting and useful discussions and promoted an exchange of experiences between countries.  These discussions were formalized through three Working Groups: Technical matters, Legal matters, Economic and Financial Strategy and Political Support in order to finalize the meeting outcomes.

One of the most remarkable achievements of this project has been the interest generated in the Region and the commitment by the delegates to achieve ESM of ULAB.

In 2001 the SBC obtained funding for a Pilot Scheme involving just 9 countries in the Region, but the presentations made by representatives from these countries in San Salvador in 2003 so inspired the non participating delegates attending the Workshop that after they returned to their own countries, without instruction or funding, they set about preparing their own ULAB inventories and strategic options. So at the final Workshop there was no less than 20 National Reports submitted to the Steering Committee. The input into this project has been outstanding.

ILMC have finalized the draft ESM Assessment Procedure in conjunction with the Green LeadTM Work Group as they have been working on a similar scheme.

 Trinidad Workshop II

In September 2006 year the Regional Strategy was agreed by the Steering Committee and its essential elements are:

  1. The development and implementation of harmonized policies for ULAB amongst the countries of the region.
  2. Improved coordination amongst the appropriate national authorities responsible for the implementation of the Basel Convention and control of customs procedures for the transboundary movement of ULAB. (This would also include improved training for customs officers through the BCRCs)
  3. Defined performance indicators for ESM and the implementation of an ESM Assessment Scheme.
  4. To implement, in full, the terms of the Basel Convention for the trans-boundary movement of hazardous waste, especially those regulations applicable to ULAB, taking into account the realities of such an undertaking in the region.
  5. Increased surveillance of ULAB movements leading to full compliance with bilateral and multilateral agreements and better control of the illicit traffic in ULAB across borders.
  6. Prepare National Strategies covering the Institutional, Welfare, Legal, and Technical Issues.

 The full version of the Regional strategy can be downloaded from the Basel Convention web site at:
http://www.basel.int/stratplan/oewg1/projdocs/elsalvador/final-reg-strategy-e.doc

The Basel Secretariat will present the outcomes and benefits of this project to the Parties in November at the COP VIII in Nairobi and seek further funding to complete the work still outstanding in the Region.

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Pilot Program Activity in Mexico

In June 2000 ILMC submitted a preliminary proposal for a project to prepare a remediation manual to guide cleanup efforts at abandoned lead mines, smelters and secondary facilities. ILMC proposed preparation of a manual to detail the most cost effective methods for minimizing general population lead exposure, with a specific early focus upon the remediation of soil at an abandoned lead smelter in Tijuana. Following receipt of a positive response from the government to ILMC's preliminary proposal, ILMC submitted a detailed plan for a project to prepare "remediation guidelines for abandoned lead mines, smelters and secondary plants". The project proposes to define the scientific principles and technical guidelines by which site assessments should be conducted, remediation strategies implemented, and adequate follow-up measures undertaken so as to ensure the efficacy of remediation efforts. Government approval of this project proposal is pending.

The first steps of the proposed project entail assessment visits to a representative number of abandoned sites to characterize the nature of contamination and to define potential exposure programs. Government assistance will be required to resolve legal barriers that presently exist and which impede forward movement on site remediation programs. Recognizing that soil removal and replacement strategies may pose financial obstacles to remediation, ILMC will be working with the international scientific community to determine the suitability of alternative approaches for interim management of contamination at specific sites. The principal remediation strategies to be evaluated include:

  • Removal of contaminated soils and replacement with uncontaminated soils, or removal of soil followed by decontamination and return of the treated soils to the original site;
  • Geochemical transformation of contaminants at abandoned sites through thermal, biological and chemical treatment methods;
  • In situ extraction and separation techniques; and
  • In situ stabilization and containment strategies.

The range of treatment options that will be applicable at a given site will be dictated by site-specific geochemical and climate parameters. Indeed, a single technology and/or methodology may not be adequate to effect remediation at any given site. Thus, the guidelines will define a decision tree work plan, whereby different treatment technologies that can be integrated so as to reduce the risk of lead exposure.

The Guidelines were published in the summer of 2006 in three formats, CD, Hard Copy and on the Internet. The Guidelines are entitled "Manual para el Manejo Ambientalmente Responsable del Plomo" and the advice in the Manual is practical and the annex has one of the best references to relevant legisaltion ever compiled.

The Guidelines are currently only available in Spanish and can be downloaded as a PDF at:

http://www.ilmc.org/Pilot%20Programs/Mexico/MANUAL.pdf

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Future Risk Reduction Activities

ILMC Pilot Programs have permitted exploration of the "levers for change" that are effective for improving the environmental performance of industry sectors in a variety of cultural and socioeconomic contexts. In accordance with recommendations made by the independent Policy Advisory Group of ILMC, future Lead Risk Reduction Program activity will build upon these experiences to explore systemic approaches that can be applied for capacity building and risk reduction. Discussions have been ongoing with several international agencies and organizations to identify new Lead Risk Reduction opportunities that would permit the implementation of risk reduction on a regional basis and/or in concert with financial assistance vehicles that provide support for the capital expenditures required for the construction of new facilities and/or the introduction of new technologies.

ILMC is thus engaged in discussions with the United Nations Environment Program (UNEP) through the Basel Secretariat (SBC)and the ILA regarding a number of initiatives associated with Lead Sustainability, the Lead Action 21 Program.

ILMC will also provide technincal support and experitise to the Blacksmith Institute's "Goldman Project" for the remediation of lead contaminated sites in Central America and the Caribbean.

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International Lead Management Center
2525 Meridian Parkway, Suite 100, Research Triangle Park, NC 27713 USA
Telephone: ++1 919-287-1872 Facsimile: ++1-919-361-1957